Application and GFE dated 7/7 completed and customer ends up not liking the rate so nothing is done with it. 7/28 Lender and customer come to an agreeable rate and produce new GFE. No new application is taken. Should we obtain a new application for 7/28 and report 7/7 as "withdrawn"? Or can we just use the 7/7 application and report 7/7 as the lock in date for the rate spread? (In house loan where we disclose lock in date as application date)
Thanks

See page D-9 of the GIR; Application date—reinstated application.

IMO you can't use 7/7 as the date you set the rate for the new request.

The way I read it in the GIR is that there would still only be one HMDA report but it would read the new application date of 7/28?

I would say your app date is still 7/7. You didn't deny, rather you were in negotiation. Technically, you probably should have sent out a counteroffer. But IMO your lock in date is 7/28 based on when the rate was agreed upon.

Bec, the way you read the GIR is correct for the application date if you are treating it as a new request. If you are treating it as an "amended" request then what GP said would be correct.