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#1860630 - 10/10/13 11:04 PM Business Loan HMDA application date
Anonymous
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Help! What're others thoughts on what is the definition of application date for business loans. My institution does not have an actual loan form for businesses and when we do a loan for businesses, like a refinance of an apartment complex, when would report the application date?

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#1860634 - 10/10/13 11:13 PM Re: Business Loan HMDA application date Anonymous
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
What was the date the customer first approached the bank about the need for financing? Generally that initial contact is memorialized in an email or memo to file.

Alternatively, if that is not a common practice, some banks use the date the bank prepares the loan request for approval. Others use the date the financial statements are received/submitted to the credit department for spreading/analysis.

Select a date or dates that work in your bank's process and be consistent.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1861195 - 10/11/13 09:53 PM Re: Business Loan HMDA application date Anonymous
Anonymous
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It would be helpful to define what is considered an application for commercial loans. In my prior institution our HMDA procedures spelled out in detail each piece of data that needed to be reported and what would be used to ensure we were consistency. We said that the application date was the earlier of receipt of the financials or the date that credit was pulled for "HMDA purposes".

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#1861205 - 10/11/13 10:14 PM Re: Business Loan HMDA application date Anonymous
Rocky P Offline
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Joined: Jun 2003
Posts: 7,650
Florida
We created a "GMI" form for the commercial loan officers. It was the basic information that is similar to Appendix B in HMDA - GIR.

We added a line on the bottom with "application date" and the LO's signature. Since they are supposed to get information at application, this was used as proof to document the date. Regulators have had no issue with it.
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#1861212 - 10/11/13 10:25 PM Re: Business Loan HMDA application date Anonymous
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Banks record this date in a number of ways, but it should have some relation to process. For example, financial statements received are date stamped in the credit department, a brief dated note is placed in file memorializing when the request was received, etc. some banks then have an application date field on the credit approval document and state the date there. You want consistency in the date used for initial application, not just people writing down random dates.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2119188 - 02/22/17 10:26 PM Re: Business Loan HMDA application date Anonymous
Anonymous
Unregistered

Customer approached bank on April 27th interested in purchasing a four unit apartment complex. LO ordered and appraisal to verify the property value. No credit terms were discussed. Is April 27th the application date for this commercial loan application? Please help. Thanks.

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#2119198 - 02/23/17 02:14 AM Re: Business Loan HMDA application date Anonymous
Rocky P Offline
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Joined: Jun 2003
Posts: 7,650
Florida
Double post - please don't waste peoples time or shop for answers.

Orig post.
"Commercial Loan Application. I have a question regarding application date. Customer approached the bank on April 27th interested in purchasing a four unit apartment. On May 17th customer decided to purchase the property and start an application with the bank. Is April 27th the date of application or is it May 17th. Please let me know. Thanks."
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Integrity. With it, nothing else matters. Without it, nothing else matters.

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