This has probably been asked and answered before but I can't find it.

If we got an online ap that was fully completed that came in on Friday afternoon but the LO was out of the office and didn't open it or work it until Monday, what is the application date for HMDA purposes? Friday or the following Monday?

We would use Friday.

Is there any guidance on this issue? We do online applications also. We have been treating the date of application the same as we would the mail. The date that someone retrieves the application is the date of application. If a customer submitted at 4:45 but we had already picked up the apps for the day, this would be dated the next business day.

Similar to mail in that mail is put in the PO Box all day, but it is not received until we go to Post Office and pick it up.

That said, I really don't think it would be much of an issue in that the LOs are pretty anxious to pick these up (they are on commission) and they generally send ETIL same or next day. So, the only thing that it might really effect is the HMDA LAR and then only possibly by one day.

Interested though in what other banks do.

for the purposes of HMDA reporting we have determined the date of application will be the date our loan officer signs the application.

we have sheets that define each data field for HMDA and where you can find that particular field in either the electronic or paper file. examples below

app date...... date of LO signature on initial 1003

income...... 1008 (monthly income x12)

purpose...... ABC Bank HMDA Purpose letter (internal document)

action taken date....note date

just for reference if you like that idea. our regulators have found these very useful.

I believe this was addressed in one of the HUD seminars.
Date of application is when the application is received, ie, opened up.
That should be the same date the LO signs it.
I wouldn't want to explain a delay between opening and signing with regard to a delayed GFE.

Thanks everyone. It seems like such a simple question but I couldn't find it defined or definitively addressed anywhere. Glad to know I'm not the only one.