Is a loan that closed 12/28/12 and disb on 1/03/13 (ROR) reportable in 2012 or 2013?

It depends on what your bank considers the action date. If you use note date, it will be 2012. If you use disbursement date for these transactions, then 2013. Be consistent.

We always use the disb date - thanks

This loan would be reportable on the the 2012 LAR. From page D-11 of the GIR:

For loan originations, an institution
generally reports the settlement or
closing date. . . . . If the disbursement
of funds takes place on a date later
than the settlement or closing date,
the institution may use the date of
disbursement. . . . .
Notwithstanding this flexibility
regarding the use of the closing date
in connection with reporting the date
action was taken, the year in which an
origination goes to closing is the year
in which the institution must report the
origination.

Sorry, I forgot about that caveat as I never used disbursement date and none of my clients do, for whatever reason.

For an automated process, disbursement date is too hard to clarify/document. Settlement/closing date is easy....assuming loan docs are dated date of settlement. It gets kind of tricky when the loan doc dates are different than the date the loan actually went to closing....which you would then have to look to the HUD Settlement Statement.