Application was submitted to refinance a HELOC into a different name (jointly owned property, awarded to the non-borrowing spouse in a divorce settlement). Counteroffered as HE Term Loan, and CO was not accepted (borrower did not qualify due to credit and DTI). Subsequently worked out with the Collections Department and resulted in a HE Term loan many months later (8 months). Is the application date the date original request was submitted? Or, some subsequent date when the contact was established with the Collections Department?

If this a current situation - 8 months ago was in 2017. You would have long ago sent them an adverse action notice. Not sure how or why you would treat the application date as going back 8 months.

We did send a Counteroffer Letter back last year on the original request. So, seems the new application date may be when there was a first connection with Collections?

We did send a Counteroffer Letter back last year on the original request.

You can't reinstate an application from a previous reporting year so you will have to determine when the new request was made.


If, within the same calendar year, an applicant asks a Financial Institution to reinstate a counteroffer that the applicant previously did not accept (or asks the Financial Institution to reconsider an Application that was denied, withdrawn, or closed for incompleteness), the reportable Application date depends on whether the Financial Institution reports the request as the continuation of the earlier transaction using the earlier transaction’s ULI or as a new transaction with a new ULI. If the Financial Institution treats the request for reinstatement or reconsideration as a new transaction, it reports the date of the request as the Application date. If the Financial Institution does not treat the request for reinstatement or reconsideration as a new transaction, it reports the original Application date. Comment 4(a)(1)(ii)-3.

Thank you for your input!