Wondering what date to report for HMDA in the following scenario.

Borrower locks rate on 1/14 for a "no points" loan. A few days later on 1/18 the borrower decides they prefer to pay points and get the lower rate. In honoring the customer's request, the bank uses the rates that were in effect as of 1/14 to price the loan, just as if the borrower had originally made the decision to go this route. This is routinely how this is handled by the bank when borrowers make this type of request.

Is this a "program change" and I should then use 1/14 as the date the rate is set because we are using pricing that was in effect as of that date?

If not a program change, should I still use 1/14 since that is the date of the pricing data that we are using, or would be 1/18 be the correct date since that is the date we made a decision on the customer's request?

HMDA is so confusing sometimes!

What rates you choose to offer the customer is a bank decision. The rate was last set on 01/18 regardless of how the rate was determined.

Thanks, Randy. Where there has been a program change, the small entity compliance guide appears to allow the bank to use the date of the original rate-lock date (page 102 of the 2018 guide). I'm just not sure if this scenario would qualify as a program change.

It doesn't sound like you changed loan programs, you just reset the rate on their current loan program.