We are getting push back from Mortgage on requiring source documents for HMDA testing instead of comparing system entries.
How can "Mortgage" document the date entered into the system is accurate? In other words how can the examiners tie back to that date.
When we used formal rate lock agreements we could always tie the system date to the date on the rate lock agreement.
Now we use a form that identifies the investor the rate is locked with, the date the rate was locked with the investor, the rate and the date the lock expires. It is initialed by the appropriate approval authority and kept with the file. We can tie the "rate set" date back to that document.
The opinions expressed are mine and they are not to be taken as legal advice.