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#1785809 - 02/13/13 09:00 PM What would be my app date?
Likes to Comply Offline
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In the mountains
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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#2083311 - 06/14/16 03:54 PM Re: What would be my app date? Likes to Comply
Compliance504 Offline
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Tennessee
I have a similar question....

Application date for HELOC 3/31 (We do not report HELOCs for HMDA)

Applicant did not qualify for HELOC so application was changed to term loan application on 5/9 (memo to file documents this)...no new application was taken on 5/9....however, GMI was collected on 5/9.....

Do we report 3/31 or 5/9 as the application date?

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#2083367 - 06/14/16 06:31 PM Re: What would be my app date? Likes to Comply
burke116 Offline
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RVA
IMO, the HELOC on 3/31 was a denial. The 5/9 term loan would be a new application for a different product and 5/9 would be the date reported on the LAR.

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#2083430 - 06/14/16 08:39 PM Re: What would be my app date? Likes to Comply
David Dickinson Offline
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David Dickinson
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Central City, NE
I agree. You have a new request for credit on 5/9th.
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#2083434 - 06/14/16 08:49 PM Re: What would be my app date? Likes to Comply
Compliance504 Offline
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Thank you both!

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#2083435 - 06/14/16 08:50 PM Re: What would be my app date? Likes to Comply
Compliance504 Offline
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BTW, Congratulations, David....saw the write up in ABA Newsbytes smile

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#2083441 - 06/14/16 08:54 PM Re: What would be my app date? Likes to Comply
David Dickinson Offline
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David Dickinson
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Central City, NE
Quote:
BTW, Congratulations, David....saw the write up in ABA Newsbytes

Thank you!
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#2083639 - 06/15/16 07:25 PM Re: What would be my app date? Likes to Comply
Colorado Girl Offline
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I believe whether your institution treated this as a continuation of the earlier transaction OR as a new transaction would guide you to the appropriate date to use.

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#2083644 - 06/15/16 07:34 PM Re: What would be my app date? Likes to Comply
raitchjay Online
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OK
I agree.
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#2083668 - 06/15/16 08:28 PM Re: What would be my app date? Colorado Girl
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Originally Posted By Colorado Girl
I believe whether your institution treated this as a continuation of the earlier transaction OR as a new transaction would guide you to the appropriate date to use.


Agree. Did you start with a new ap number or reactivate? It matters.
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#2083729 - 06/16/16 01:42 PM Re: What would be my app date? Likes to Comply
RR Joker Offline
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The Swamp
I also agree. Same calendar year...it could be done either way.
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