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#2299423 - 07/17/24 01:39 PM Re: Application Date Dan Persfull
LSB HMDA Offline
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Joined: Feb 2023
Posts: 22
To clarify, by "complete application" I mean that we have the information we need to take the file from "inquiry" to "application". Again, since HMDA does not define what an "application" is, we take TRIDs definition needing name, SSN, property address, and at least stated/estimated amounts for income, property value, and loan amount. We do not require verification documents (W2s, paystubs, etc.) but do require the six pieces of information per guidance from a Banker's Compliance Consulting training

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HMDA

#2299427 - 07/17/24 02:15 PM Re: Application Date LSB HMDA
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,749
Bloomington, IN
but do require the six pieces of information per guidance from a Banker's Compliance Consulting training

I have the upmost respect for the people at BCC and I have sat in on several of their trainings but requiring the 6 pieces of information before you consider having a HMDA covered application is incorrect advice IMO.

LSB HMDA today I go to your website and fill in the following information on your application form - Name: Dan Persfull, address - 123 Main St - Anytown, IN, Amount requested - $130,000 , Purpose - home improvements.

I just gave you an online application, as incomplete as it may be, that is subject to HMDA. The application date would be today's date.. This is assuming you accept applications through your bank's webpage.


You might want to discuss this with your Examiner In Charge.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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