HMDA-action taken date

Posted By: Simply Sheldon

HMDA-action taken date - 08/01/06 04:35 PM

We have recently had a finding that stated that the action taken date should be the date the loan was funded. However, because of the 3 day right of recission wouldn't we be able to consider the action taken date the date of the loan?
Posted By: Skittles

Re: HMDA-action taken date - 08/01/06 04:36 PM

You can do it either way (I always think the date of the note works best). Just be consistent for the entire year.
Posted By: Dan Persfull

Re: HMDA-action taken date - 08/01/06 04:47 PM

Using the note (closing) date is, IMO, the most consistent and less prone to reporting errors. But as Skittles said Reg. C gives you the option of using the closing date or the settlement date. See page D-11 and -12 of the GIR.
Posted By: Simply Sheldon

Re: HMDA-action taken date - 08/01/06 05:47 PM

Thank you for your input and references. Very much appreciated.
Posted By: Al Miller

Re: HMDA-action taken date - 08/01/06 07:00 PM

The last bank I was at was a major refi lender. We used the date the last person signed the Deed of Trust as we could also use that date for beginning rescission. FDIC had no problem with that date. As was said, consistency is the key.