If 2004 is our first year of HMDA reporting, do I use transition rules? Or do I only report applications received in 2004? (In this case, I have an application received in 03 and closed in 04)

The FFIEC's Guide to HMDA Reporting states that "A LAR for a given calendar year must contain all reportable applications that reached final action (e.g., origination of a loan, denial of an application) in that year, regardless in which year the application was submitted."

The transition rules applied ONLY to banks that were already HMDA reporters in 2003. You only report applications RECEIVED in 2004.

If this loan was closed in 2004, wouldn't it be reportable in 2004 even though the application was actually received in 2003 and regardless of whether or not they were HMDA reporters before?

Our bank is in the same situation (not HMDA bank until 2004)and we were doing the transition rules for applications taken in 2003 and action taken in 2004.