We closed a loan on 6/18/13, however the original application was taken on 8/15/12 and was approved on 9/12/12 but did not close due to title issues. There was a counter-offer on 9/5 and the loan did not go forward until a new application was signed on 2/27/13. All current financial info was received and a new commitment letter issued on 4/8/13 and I have been assured by the VP of lending that there is no issues with the timeframe. I do have a HMDA question regarding the reporting of the loan and what application date should be used. This loan was not reported last year and they are using the same account number issued last year. I am confused....Please advise which app date to use.

Ordinarily I would say go with the original application of 8/15/12, there are reasons for the delay and it is not as unusual as you think. However, why the new application signed on 2/27/13, was that just to update information?

The 2/27/13 app was added to update the file. Just did not want this to be an issue for HMDA reporting. Thank you!