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#2053991 - 12/14/15 04:16 PM Application Date for PreApproval
HMDA is my life Offline
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Joined: Oct 2015
Posts: 55
For HMDA what is the Application Received date for a preapproval? For preapproval not requested we are using the date we received all 6 pieces of information needed for RESPA, but on a preapproval requested what is the recommended date? I am torn on this because I can see using the RESPA date, but becaise preapproval is a HMDA thing I want to use the date preapproval was requested.

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#2053999 - 12/14/15 04:26 PM Re: Application Date for PreApproval HMDA is my life
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
Pre-approval application date is the date you received the pre-approval request.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2054001 - 12/14/15 04:28 PM Re: Application Date for PreApproval HMDA is my life
HMDA is my life Offline
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Joined: Oct 2015
Posts: 55
I would agree Dan. Where can I find that in writing?

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#2054019 - 12/14/15 05:38 PM Re: Application Date for PreApproval HMDA is my life
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
GIR - page D-7. A pre-approval request is a reportable application for HMDA therefore you would report the date that application is received.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2054020 - 12/14/15 05:38 PM Re: Application Date for PreApproval HMDA is my life
HMDA is my life Offline
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Joined: Oct 2015
Posts: 55
This is the situation...We have an application that a pre-approval was requested and approved. The applicant found a property, a commitment letter was issued, and we started processing the application. For whatever reason the applicant has said thanks but no thanks. I say the app date is the day they requested pre-approval (actually not reportable because I would call this application pre-approval requested but not accepted). Others are saying this application "converted" (to what I don't know) and we should report this as approved but not accepted. what is correct?

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#2054024 - 12/14/15 05:50 PM Re: Application Date for PreApproval HMDA is my life
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
Others are saying this application "converted"

That would be true for a pre-qualification request since pre-qualifications are not applications under HMDA, but if you have a qualified pre-approval program then the date of application is the date the pre-approval was requested since that request is an application under HMDA.

Since a property was identified this request would be reported as an approved but not accepted with the application date the date the pre-approval request was received and a Code 1 under Pre-approval.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2055054 - 12/18/15 08:36 PM Re: Application Date for PreApproval HMDA is my life
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,266
Along these same lines, we have a request that started as a pre-qualification, then "converted" to a qualified pre-approval request three days later. The application in the file is dated the date the pre-qual was requested, so it's three days prior to the application date reported on the LAR for the pre-approval. These dates are all tracked and documented in our system, but how do you prove the pre-approval application date to an examiner? Would a screen print of the system's conversation log suffice?

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