When does the “application process” end? We need to give our lenders guidance so that they know when they need to collect DI information based on visual observation or surname when they meet with the client face-to-face after an application was submitted where the DI information was not completed. Is the “application process” considered complete when a decision has been made? I’ve read other threads where someone said, “If you have yet to make a decision, you are still within the application process whether you feel you have a complete application or not.” So, is the bright line when a decision has been made?? The paragraph below refers to “at loan closing” as too late.

From Appendix B to Reg C:
If application begins by mail, internet or telephone and applicant does not provide the requested information and does not select "I do not wish to provide this information" and then meets with the bank in person to complete the application, the bank must request the applicant's information when the bank meets with the applicant in person. If the applicant does not provide the requested information during the in-person meeting, the bank must collect the information on the basis visual observation or surname. If the meeting occurs after the application process is complete (for example, at loan closing), the bank is not required to obtain the information.

Thank you!

I don't know that you're going to find a definitive answer to this question. I would start with:

(b) Application—(1) In general. Application means an oral or written request for a covered loan that is made in accordance with procedures used by a financial institution for the type of credit requested.

and that doesn't put any definitive clarity. IMO, it's up to how you want to define "application" for your bank as it relates to HMDA, with the caveat mentioned in the commentary that you posted above--the bank's definition seemingly isn't allowed to expand it's definition of "application" to include activity that happens at loan closing.

For me, if there's no missing information that MUST be gathered in order to report it for HMDA, then the HMDA application process is over. For example, if an applicant hasn't indicated a loan purpose, or hasn't entered a subject property address, or hasn't entered an amount requested--i would call that an incomplete application for HMDA. Just my humble opinion.

That is very helpful! Thank you very much!

I see an issue with the original question posed. I think your application process is flawed.
Lenders cannot go back and give face to face/surname replies for DMI if they met face to face without having asked the questions.
Your lenders should be trained to ask the questions at time of meeting... period.
If, when asking the question the applicant replies "I do not wish to reply" then, and only then, is a lender charged with giving visual answers.

If you're saying an application was submitted via internet or mail without DMI, then that's what you report.

As for what constitutes an "application," while Reg C allows you to define that yourself, I've found that the vast majority go with the TRID definition rather than create a separate one for HMDA. That means, if you have the six pieces that trigger an LE, you have an application for Reg C too.