HMDA, Home Purchase Loans and the "Date of Action" - Mary Beth Guard
HMDA, Home Purchase Loans and the "Date of Action"
Answer by Mary Beth Guard, BOL Guru
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 >
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.
First published on BankersOnline.com 1/10/05
First published on 01/10/2005