Action Date of Refi Loan on HMDA LAR

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Question:

When completing the Action Date of a refi loan on the HMDA LAR, should the actual closing date of the loan document or funding date following the right of rescission be used?

Answer:

Per the HMDA Getting It Right Guide, either is correct. A bank should be consistent in the date chosen within a product line.

Page D-10:

6. Action taken dateâ€”originations. For loan originations, an institution generally reports the settlement or closing date. For loan originations that an institution acquires through a broker, the institution reports either the settlement or closing date, or the date the institution acquired the loan from the broker. If the disbursement of funds takes place on a date later than the settlement or closing date, the institution may use the date of disbursement. For a construction/ permanent loan, the institution reports either the settlement or closing date, or the date the loan converts to the permanent financing. Although an institution need not choose the same approach for its entire HMDA submission, it should be generally consistent (such as by routinely using one approach within a particular division of the institution or for a category of loans). (Appendix A of this part, Paragraph V.B.3.)

First published on BankersOnline.com 3/18/13