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#591546 - 08/01/06 04:35 PM HMDA-action taken date
Simply Sheldon Offline
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Simply Sheldon
Joined: Oct 2005
Posts: 2,047
S.E. TX
We have recently had a finding that stated that the action taken date should be the date the loan was funded. However, because of the 3 day right of recission wouldn't we be able to consider the action taken date the date of the loan?

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Lending Compliance
#591547 - 08/01/06 04:36 PM Re: HMDA-action taken date
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,963
TN
You can do it either way (I always think the date of the note works best). Just be consistent for the entire year.
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#591548 - 08/01/06 04:47 PM Re: HMDA-action taken date
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,762
Bloomington, IN
Using the note (closing) date is, IMO, the most consistent and less prone to reporting errors. But as Skittles said Reg. C gives you the option of using the closing date or the settlement date. See page D-11 and -12 of the GIR.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#591549 - 08/01/06 05:47 PM Re: HMDA-action taken date
Simply Sheldon Offline
Diamond Poster
Simply Sheldon
Joined: Oct 2005
Posts: 2,047
S.E. TX
Thank you for your input and references. Very much appreciated.

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#591550 - 08/01/06 07:00 PM Re: HMDA-action taken date
Al Miller Offline
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Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
The last bank I was at was a major refi lender. We used the date the last person signed the Deed of Trust as we could also use that date for beginning rescission. FDIC had no problem with that date. As was said, consistency is the key.
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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