Action Taken Date

We have a HELOC that was modified into a HELOAN last year and I need to confirm what to put for the action taken date. Here's the scenario:

Loan documents (Note, Mortgage) are dated 9-15-10 (which was the maturity date fo the HELOC), but actually were signed by the borrower on 10-28-10.

The HUD was dated 10-21-10 (not sure why but that's another matter), but actually signed 10-28-10.

As far as I am concerned, the action taken date is 10-28-10, but when it was booked on the system, the date was 9-15-10.

Am I on the right track using 10-28?

The customer became liable on 10-28 when the documents were signed. The 9-15 date is so the lein position remains. If the customer did not sign the new docs would not be valid.

Action Date 10-28

Yes. They are backdating the note & system to avoid having to collect additional interest from the borrower and to hide a delinquency.


Hopefully all your required closed-end disclosures & timing requirements - ETIL, GFE, MDIA, HPML, etc were met.

Most definitely...thanks!!