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#2235286 - 04/20/20 08:01 PM No DOB on Application
Fiddlesticks Offline
Member
Joined: May 2015
Posts: 62
We received an application online for purchase of a property that is out of our lending area. The application did not have a date of birth and no credit bureau was pulled as a SSN was not provided so we can not determine the applicant's age. What should we report on our LAR for age? Thank you.

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#2235297 - 04/20/20 10:32 PM Re: No DOB on Application Fiddlesticks
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
Lending is not my area of expertise but as far as I can tell, you really don't have an application yet.
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A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
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#2235314 - 04/21/20 03:08 PM Re: No DOB on Application Fiddlesticks
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
You have an application, it's just incomplete. You're asking about how to report age on the LAR, but I need to know what you did with the application. Did you approve it? You could send an Notice of Incompleteness and request the applicant's SSN and DOB.
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David Dickinson
http://www.bankerscompliance.com

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#2235343 - 04/21/20 07:18 PM Re: No DOB on Application Fiddlesticks
Fiddlesticks Offline
Member
Joined: May 2015
Posts: 62
It was denied due to being outside of our lending area.

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#2235347 - 04/21/20 07:44 PM Re: No DOB on Application Fiddlesticks
Inherent_Risk Offline
Platinum Poster
Joined: Jan 2017
Posts: 573
I don't know how you define an application at your institution, but that would not be an application under HMDA at ours.

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#2235360 - 04/21/20 08:31 PM Re: No DOB on Application Fiddlesticks
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Inherent_Risk: My point is that it's an application. It isn't a completed application. You have a request for credit. I'm not sure how you can say that's not an application. If you hanging you hat on the "made in accordance with procedures" part of the definition in §1993.2(b)(1), I think it's thin ice, but that's not really what this thread is about.

Fiddlesticks: Since you denied it, you can't really go back to them now. The FIG states:
Enter, in numeral form, the age, in years, of the applicant or borrower, or of the first co- applicant or co-borrower, as applicable. Age is calculated, as of the application date, as the number of whole years derived from the date of birth shown on the application form. Or enter the applicable Code from the following:
Code 8888—Not applicable


I would report 8888 as you don't have "date of birth shown on the application form."
_________________________
David Dickinson
http://www.bankerscompliance.com

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