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#526179 - 04/04/06 01:05 PM HMDA
jmd Offline
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Joined: May 2002
Posts: 233
Can different dates be used in different lending departments for the date application received entered on the HMDA LAR? In the consumer and residential lending areas the date the application is received is used. In the commercial lending area, the date on the application is used. As long as the dates are consistently used in each lending area, is this in compliance with HMDA?

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Lending Compliance
#526180 - 04/04/06 01:11 PM Re: HMDA
Love those Regs Offline
Gold Star
Joined: Apr 2002
Posts: 292
Southern State
Appendix D of HMDA Reporting Getting It Right on page D-9 states "in reporting the date of application, report the date the app was received or the date shown on the app." It goes on to say you do not have to choose the same approach for the entire submission, it should generally be consistent - such as by routinely using one approach within a particular division of the institution. So, you should be ok as long as each dept. is consistent.
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