HMDA, Home Purchase Loans and the "Date of Action"
Answer by Mary Beth Guard, BOL Guru Guru BIOS
Question: The part of the HMDA reg relating to date of action for HMDA reporting is not clear for a home purchase loan.
Isn't the "date of action" on a loan that is classified as a "Purchase Loan" where the borrower is using also the equity in their home to purchase another home (two properties on the note) going to be the Right of Rescission disbursement date for the date of action for HMDA reporting?
Answer: According to my colleague, Andy Zavoina, the "Getting It Right" booklets tell you that the "date of action" is the settlement or closing date for originated loans. Andy says that, in his experience, most lenders use the closing/note date. It is easy to track to and consistent for all loans, less loans you purchase. Those use the date you actually purchase the asset. The date of rescission could be used if done consistently on all applicable loans. However, for training sake, he suggests the KISS method and just using the note date.
The original version appeared in the July/August 2004 edition of the Oklahoma Bankers Association Compliance Informer.
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