We are auditing our HMDA LAR information and have found several discrepancies on the Action Date. When verifying records, our Centrax extract is off by 1 - 4 days from the documented Action Date. Is this allowable? Do you know where I might locate this in the regulation?

Any help is greatly appreciated. Thank you in advance.

Personally, I am not sure how you can justify action dates that are off for some random reason by 1-4 days.

I agree with Randy, you will want your action dates to be accurate. Any idea why the dates are off?

Could it have to do with rescission?

And I agree that all data should be accurate.

The mortgage department says sometimes they were not getting the paperwork in time for the wire to be sent out the same day. The status date updates in Encompass at the time they finalize the loan, which could be the next business day.

Is there anything in the regulation that says these dates should match? Mortgage wants proof.

No they are not rescission. All are purchased loans. We checked for that.

The action date used for a purchased loan is the date of the purchase. We don't get any more guidance than that . 12 CFR 1003.4(a)(8)(ii) and comment 4(a)(8)(ii)-6.

So, that could mean the agreed-upon date for the purchase, the date the purchase docs are signed, or the actual date funds are advanced to purchase the loan, I think. You would want to select what your bank means by "date of purchase" and stick to it.