Two LAR entries or one?

Posted By: AuditorK

Two LAR entries or one? - 12/29/11 04:27 PM

We take an application on 9/1 for $100,000 to refinance an existing mortgage loan. On 10/15 the customer changes his request amount to $110,000. Bank approves the increased request and the loan is closed on 11/1. How is this recorded on the LAR?

I don't believe how we currently have it recorded is correct. We have the orginal application listed as date taken as 9/1 and "withdrawn" on 10/15. Then we have another LAR entry for the loan at the new amount with a date received of 10/15 and action taken as 11/1.
Posted By: AFaquir

Re: Two LAR entries or one? - 12/29/11 04:24 PM

Did the customer complete a brand new app on 10/15?

IMO this is one HMDA reportable loan. The 9/1 app date and the closed loan amount of $110 and the 11/1 approval date.
Posted By: AuditorK

Re: Two LAR entries or one? - 12/29/11 06:47 PM

Yes, a new application was done for the new $$ request. I still feel this was just a continuation of the orignal application, just a changed loan amount.
Posted By: Kathleen O. Blanchard

Re: Two LAR entries or one? - 12/29/11 08:12 PM

If the bank received a new application, then the LAR should handle these as separate requests (and they should have been processed as separate requests). The first request, if approved, would be approved not accepted. If an approval had been made, the bank cannot report as withdrawn even though the customer changed his mind. It is approved not accepted.

The second one is an origination.
Posted By: AFaquir

Re: Two LAR entries or one? - 12/29/11 09:06 PM

Concur with Kaybee...

Two apps, two loans... one app, one loan. HMDA is an "app" driven regulation.