On your CRA and HMDA loan registers, under the field of action date, are you reporting the note date or the disbursement date? Have you ever had a regulator question which one you were using?

For HMDA this is addressed in the Getting it Right booklet. Use the settlement date and be consistent.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

We use the disbursment date for CRA. Check the reg., but I think it is ok to use the note date too--as long as you are consistent in which date you use.

From page 21 of the Getting It Right booklet:

"Date of action taken. Enter the settlement or closing date for originations. For applications that did not result in an origination, enter the date when the action (loan denied, file closed for incom-pleteness, application approved but not accepted) was taken or when the notice was sent to the applicant. For an application that was expressly withdrawn by the applicant, you may enter either the date shown on the applicant’s letter or the date that you received the letter or notice. For loans that your institution purchased, enter the date of the purchase. (See the Staff Commentary in Appendix D to this Guide for additional guidance concerning the date to be entered for other situations.)"

If your note date is the same as the settlement or closing date you're fine.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.