Hello All,

My Credit Union originates manufactured home loans and while this type of loan does not meet the TRID definition we do obtain enough information, under Reg B, to make a credit decision. The issue I am running into is the amount of time that lapses between when the application is approved and when the loan is funded. When a borrower is approved we issue a 90-day commitment letter to the borrower so the retailer can begin production on their home. We have found this process can take longer than 90 days depending on what is happening in the manufacturer's space, which could extend the commitment letter based on our policies and procedures.

My question is how should the approved loan be reported on the HMDALAR if the application is received at the end of one year and the commitment letter extends into a new year (i.e. application was approved in 2020 and is funded in 2021).

Any guidance you are able to offer is greatly appreciated.

Action date is either the loan date, account opening date, or the disbursement date. The approval date isn't an option.

5. Action taken date—originations. For covered loan originations, including a preapproval request that leads to an origination by the financial institution, an institution generally reports the closing or account opening date. For covered loan originations that an institution acquires from a party that initially received the application, the institution reports either the closing or account opening date, or the date the institution acquired the covered loan from the party that initially received the application. If the disbursement of funds takes place on a date later than the closing or account opening date, the institution may use the date of initial disbursement. For a construction/permanent covered loan, the institution reports either the closing or account opening date, or the date the covered loan converts to the permanent financing. Although an institution need not choose the same approach for its entire HMDA submission, it should be generally consistent (such as by routinely using one approach within a particular division of the institution or for a category of covered loans). Notwithstanding this flexibility regarding the use of the closing or account opening date in connection with reporting the date action was taken, the institution must report the origination as occurring in the year in which the origination goes to closing or the account is opened.