Trying to find the most common and compliant way to report the action taken date when a Notice of Incompleteness is used. The date of the notice, or the date which the applicant would have needed to provide the additional information? I feel we've taken action on the date of the notice, but I can also see how using the "must provide by XX date" is acceptable since this is when we will actually close out the file. Is this a pick a way and stick with it or am I missing a more official interpretation somewhere?

Thank you!

2. Action taken date—applications denied and files closed for incompleteness. For applications, including requests for a preapproval, that are denied or for files closed for incompleteness, the financial institution reports either the date the action was taken or the date the notice was sent to the applicant.

Pick one and stick to it.

Thank you!