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#1698365 - 05/10/12 07:30 PM Application Date
Msunset Offline
100 Club
Msunset
Joined: Jan 2008
Posts: 145
In an application received by a broker, do we report the application date received by the broker or the date that it was received by the institution.

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#1700551 - 05/17/12 03:06 PM Re: Application Date Msunset
Pamlissa Offline
100 Club
Joined: Oct 2009
Posts: 115
Rosemont, IL
What date you report depends on the policy at your institution. The last bank that I worked for reported the date the borrower signed (not the date printed next to the loan officer's name by the LOS) for the application date on third party applications. Where I currently work, we report the date that our institution received the application in our underwriting department. Either of these are acceptable, though I prefer the current policy I am working under. Consistency in your reporting is what counts. Remember, the broker may have shopped the loan around for months to different lenders before it arrived at your institution.

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#1701255 - 05/18/12 06:24 PM Re: Application Date Msunset
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,403
This is where you need to be careful about overlapping regulations.
We use the same date for HMDA and RESPA.
You need to clarify what your bank's policy is and follow it so you don't trip yourself up with examiners.

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#1701274 - 05/18/12 06:51 PM Re: Application Date Msunset
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,568
Bloomington, IN
We use the same date for HMDA and RESPA.

If you have a pre-approval program this procedure won't work.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1701591 - 05/21/12 03:01 PM Re: Application Date Msunset
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,403
Agreed.

It wouldn't be a RESPA application without the address anyway so your procedure would need to address a preapproval situation specifically.

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