Customer begins application saying they want X product, assume the transaction is HMDA reportable. During the process, there's a change in direction and now the customer wants Y product. Assume we gave disclosures at the time of X product choice and new disclosures at the time of Y product choice. At this time, we don't do a whole new application document when it changes to Y, just note in the file the customer's product change request.

Is the HMDA application date the original X product choice date or the date it changed to Y product choice?

What do all of you do in terms of a whole new application document when product choices change?

Consider it a variation of a counter-offer and use the original date of application.

Thanks. Do you do a new application with the new product / terms noted - i.e., started out conventional variable; went to fha fixed. New application?

Our commitment letter indicates the product, etc. and the final application will confirm the product they went with.

IMO, you only get one crack at the original application. Changes made after that original application is taken should be shown on the final application signed at the closing.

Just curious - do you do a final at closing application for all types of consumer loan transactions? Do you do commitment letters on all types of consumer loan transactions? If not, where do you cut it off - only those involving residential real estate? Only first mortages?

I'm trying to write more specific consumer loan application process / procedures (RE and non-RE) and this is something we've thrown around but not sure how far to take it. Curious of your practices.

My FI is a bank for banks that doesn't do the myriad different types of consumer loans so I can't speak to that part of your question. Because your post is in this forum (HMDA) I assumed you were talking about real estate lending. With that in mind, we do final applications for all our real estate closings, first and second mortgages.

Thank you.

Revisiting this thread for a related question. If the original application is for a reportable HE loan, but midway through the process the customer decides they'd rather have a HELOC and we end up originating the HELOC, would we report the HE at all?

Note - we don't report HELOCs.

Not unless you required them to withdraw the application and submit a new one.