We have a situation where a woman called wanting to make repairs to her elderly mother's home and said she was her mother's power of attorney. When we received the application the mother was listed as borrower and the daughter had also completed the co-borrower section; however, the daughter did not complete any other information about herself on the application or even sign it as co-borrower. All of the supporting documentation was from the mother.

Also, when we received a copy of the POA, it was dated two days after we had received the initial application.

Do I consider the daughter an applicant?

It doesn't sound like you have a valid application at all, let alone one that is HMDA reportable.

The daughter had no right to initiate anything on her mother's behalf until she had POA powers which wasn't until AFTER your application date.

You'll need to start all over again. This time the daughter should not include any information about herself on the application at all.

I'm sorry; I misunderstood. The POA was in effect when we received the application, just not at the time of the initial contact.

Most likely she was just giving you her contact information as the Attorney in Fact for her mother. Pick up the phone and call her to ask what her intentions were. If my assumption is correct put a note in the file to that effect.