I have looked at the GIR and the HMDA thread and I just can't seem to get my head around on this. We are doing renewing a construction loan and putting into the permanent phase, termed out and such. The new note replaces the existing note. We are reporting it as a purchase but are at a loss with the application date. Do we use the application date of the original construction loan, or the permanent fincancing date. The only thing I wonder is that the customer didn't actually fill out an application so therefore would it be appropriate to use the same date as the action taken date?

When the customers came to you and applied to build a house, your bank broke the request into 2 loans - a construction phase followed by a permanent phase. There's 1 application and 2 loans. The application date for both loans is the original date.

An application is a request for credit. It's not a piece of paper. So when you say "the customer didn't actually fill out an application", it doesn't matter. Verbal applications are still applications for HMDA and Reg B.

Good point about the applications not being a piece of paper. So the original application when we took the request for credit at the time of construction would be the application date on HMDA.

Why doesn't the HMDA GIR manual address that specifically is what I am wondering. OR maybe it does and I missed it?

Why doesn't the GIR address this? Because it's really a Reg B issue.