What would be my app date?

Customer's HELOC matured and is applying to refinance to continue as a HELOC. HELOC app is denied but counter offer is given to amortized the debt. Same application is used for both transactions with a note at the top of the app with the date of the denial and counter offer.

The app date was 11/5/12 and the counter offer was given and accepted on 11/14/12.

The loan is now HMDA reportable. Is my application date 11/5/12 or 11/14/12?

I have a similar question....

Application date for HELOC 3/31 (We do not report HELOCs for HMDA)

Applicant did not qualify for HELOC so application was changed to term loan application on 5/9 (memo to file documents this)...no new application was taken on 5/9....however, GMI was collected on 5/9.....

Do we report 3/31 or 5/9 as the application date?

IMO, the HELOC on 3/31 was a denial. The 5/9 term loan would be a new application for a different product and 5/9 would be the date reported on the LAR.

I agree. You have a new request for credit on 5/9th.

Thank you both!

BTW, Congratulations, David....saw the write up in ABA Newsbytes

Thank you!

I believe whether your institution treated this as a continuation of the earlier transaction OR as a new transaction would guide you to the appropriate date to use.

I agree.

Agree. Did you start with a new ap number or reactivate? It matters.

I also agree. Same calendar year...it could be done either way.