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HMDA Preapproval Question
by Dan Persfull, BOL Guru
Guru BIOS
Question: Now that a request for a preapproval is an application under HMDA, what date do we report? The date the customer first contacts us? The date we pull a credit report? The date we send a written preapproval? Or should we just pick one and be consistent?
Answer: Date of application - the date the pre-approval request was received.
Date of Action -
Originations - the note date.
Denials - we use the date the AAN is mailed
Withdrawn - not reportable.
Approved but not Accepted - optional reporting. If you report, report the date you close the file.
Closed for Incompleteness - use the date you close the file.
First published on BankersOnline.com 7/04/05
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