HMDA – Which Date Do We Use?
Answer by David Dickinson, BOL Guru Guru Bio
Question: We have several construction loans that we are now having to modify since the customer is unable to sell the property at this time. I understand that since we are changing the terms and class code description from a construction to an investment real estate loan we need to report to HMDA. My question is do we still use the original construction application date and then the action taken date will be the MOD/Change date?
Answer: Use the date the customer requested (or you decided to) change the loan and modify it. This was the new application date.
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