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#2247357 - 01/08/21 02:14 PM Action Date
Compliance_12345 Offline
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Joined: Jan 2021
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We are auditing our HMDA LAR information and have found several discrepancies on the Action Date. When verifying records, our Centrax extract is off by 1 - 4 days from the documented Action Date. Is this allowable? Do you know where I might locate this in the regulation?

Any help is greatly appreciated. Thank you in advance.

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#2247360 - 01/08/21 02:30 PM Re: Action Date Compliance_12345
rlcarey Online
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rlcarey
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Personally, I am not sure how you can justify action dates that are off for some random reason by 1-4 days.
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#2247362 - 01/08/21 02:33 PM Re: Action Date Compliance_12345
Adam Witmer Offline
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I agree with Randy, you will want your action dates to be accurate. Any idea why the dates are off?
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#2247366 - 01/08/21 02:54 PM Re: Action Date Compliance_12345
Skittles Offline
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TN
Could it have to do with rescission?

And I agree that all data should be accurate.
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#2247369 - 01/08/21 03:18 PM Re: Action Date Adam Witmer
Compliance_12345 Offline
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The mortgage department says sometimes they were not getting the paperwork in time for the wire to be sent out the same day. The status date updates in Encompass at the time they finalize the loan, which could be the next business day.

Is there anything in the regulation that says these dates should match? Mortgage wants proof.

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#2247370 - 01/08/21 03:20 PM Re: Action Date Skittles
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No they are not rescission. All are purchased loans. We checked for that.

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#2247527 - 01/12/21 06:58 PM Re: Action Date Compliance_12345
John Burnett Offline
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Cape Cod
The action date used for a purchased loan is the date of the purchase. We don't get any more guidance than that . 12 CFR 1003.4(a)(8)(ii) and comment 4(a)(8)(ii)-6.

So, that could mean the agreed-upon date for the purchase, the date the purchase docs are signed, or the actual date funds are advanced to purchase the loan, I think. You would want to select what your bank means by "date of purchase" and stick to it.
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