Answer:
Answer by David Dickinson: There is no firm answer to your question for every application. Typically, you can't pull a credit report unless you already have an application, so the application date is the same OR BEFORE the date the credit report is pulled.
Read the definition of "application" in Regulation B Section 1002.2(f) and its commentary. An application is simply a request (oral or written) for credit.
As I stated in the beginning, this is a complicated topic. I teach a webinar for BOL on this topic. You can find more information here.
Answer:
Answer by Kathleen Blanchard: There are quite a few possibilities for an application date for commercial lending; it is very specific to the bank's or even the product's process.
A few examples are:
- date financial statements are submitted for spreading
- date of credit approval memo (that documents the request)
- date the customer signs a term sheet and pays a fee, having decided upon the bank where it will pursue the loan request - the bank then commences actual due diligence and negotiates the terms of the proposed loan.
If a customer is not new to the bank and has either recently borrowed or has submitted all information for its annual review recently, the application date (and completed application date) can be the date the customer first relays the request to the bank.
First published on BankersOnline.com 2/13/12
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