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#2190920 - 08/28/18 08:02 PM Action Date for CRA Small Business reporting
learningdaily Offline
Junior Member
Joined: Dec 2013
Posts: 33
Well - up until now I have always thought the 'Action Date' was as simple as one could get until recently joining a bank which has been around for quite a while and discovering their established process (that has survived multiple data integrity compliance exams) mandates the system date instead of the Note date as their 'source document'. To be more specific, the action date for a new loan is the date the loan was booked to the system AND NOT the Note date.

So - here I am. Curious. Who out there interprets the action date similar to the above? I've only been in compliance for about 5 years and realize some things have changed over the years...is it possible using a system date was once the norm and the bank has just not updated their process?

Thanks for the feedback.

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CRA
#2191406 - 08/31/18 03:49 PM Re: Action Date for CRA Small Business reporting learningdaily
mrogersfib Offline
100 Club
Joined: Aug 2018
Posts: 116
This might seem counter intuitive, but providing the date of origination is considered as optional. We provide it to examiners to make their job easier. During their integrity exam they utilize the unique identification number of the loan, or the note associated to its loan file, and validate the "origination date" of a loan which is when a deal is considered legal. For some banks, the signature is not the legal binding completion of the deal, but when the deal has been recorded on the books, or when the customer has received and begin benefiting from their funds.

This is an important thing to monitor as a colleague at my previous employer got caught up in a situation that our department practice where we denied any loans that came into our reports after the last day of February. We reported a loan for CD, but it had been previously denied because it fell into our denial window. We essentially failed our entire data integrity exam because of one loan out of 2800 CD loans. The industry currently seems to really shy away from resubmission, but our examiners demanded that we re-file no matter the circumstance. Though interestingly if we had planned for the situation--we could have just denied the CD loan, and no one would of known any better.

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#2191421 - 08/31/18 04:25 PM Re: Action Date for CRA Small Business reporting learningdaily
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 778
Originally Posted By learningdaily
Well - up until now I have always thought the 'Action Date' was as simple as one could get until recently joining a bank which has been around for quite a while and discovering their established process (that has survived multiple data integrity compliance exams) mandates the system date instead of the Note date as their 'source document'. To be more specific, the action date for a new loan is the date the loan was booked to the system AND NOT the Note date.

So - here I am. Curious. Who out there interprets the action date similar to the above? I've only been in compliance for about 5 years and realize some things have changed over the years...is it possible using a system date was once the norm and the bank has just not updated their process?

Thanks for the feedback.


Out of curiosity, are you reporting the loan amount on the note or the loan amount at the time of booking? There could be a difference, correct?

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#2191544 - 09/04/18 02:35 PM Re: Action Date for CRA Small Business reporting Tennismom
learningdaily Offline
Junior Member
Joined: Dec 2013
Posts: 33
@ Tennismom: The loan amount on the note is reported.

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