Customer's HELOC matured and is applying to refinance to continue as a HELOC. HELOC app is denied but counter offer is given to amortized the debt. Same application is used for both transactions with a note at the top of the app with the date of the denial and counter offer.
The app date was 11/5/12 and the counter offer was given and accepted on 11/14/12.
The loan is now HMDA reportable. Is my application date 11/5/12 or 11/14/12?
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