I need some clarification please regarding Action Date and HMDA.

Here is the example - the date on an adverse action is 05.15.12. The reason for the AA is due to an incomplete application to make a credit decision. The client is given until 06.29.12 to provide the inforamtion. The client did not supply the information so the file was closed on 06.30.12.

Here is the question. What date do we use as the action date for HMDA? Usually we use date of the AA. In this scenerio would we use the AA date or the 06.30.12 date the file was closed?

If this is the case, what happens if the timeframes cross over quarter end periods and your LAR needs to be updated 30 days after each quarter. It seems like a mess to keep track of.

Thanks for the help -

Are you sending an adverse action notice or a notice of incompleteness. These are two different type of notices and will impact your reporting.

The AA's are being sent as a notice of incompleteness, and the client has until XXX date to get us the information otherwise we would note the file closed for incompleteness.

Thanks-

If you are sending them a AAN, the date of action is the date of the notice if the applicant does not accept the counter-offer. If they accept, then it would be an originated loan and the date of action would be the loan closing date.

AANs are for denials. The day you deny would be the action date for HMDA.

Notice of imcomplete is just that, a notice.
You give the borrower a drop dead date to comply by.
If they do not comply by that date, then the file is closed for incompleteness so the drop dead date becomes your action taken date.

Don't worry about a loan that crosses over the end of the quarter. My LAR has holes in it all year long. Most of them disappear when I upload the next quarter. AT the end of the year, you have to fill in any that are outstanding before you file.

It seems to be so messy. You would think that the day you give a notice would be the action date. HMDA is so confusing - Thanks for the information though.

You can do either:

For applications and preapprovals
denied, applications
and preapprovals approved
but not accepted by the
applicant, and files closed for
incompleteness, enter the
date that the action was taken
by your institution or the date
the notice was sent to the
applicant.