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Action Date for CRA Small Business Loans

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CRA Question: The action date should be the note date, correct? We are booking commercial loans with the "funding date" as the original date on the system, not the note date. Shouldn't the loan processing department use the "actual" note date as the original date?

I am a small bank and not subject to CRA reporting, but I would think the action date, or any other date would mirror the guidelines provided by HMDA.

Action taken date -- originations. For loan originations, an institution generally reports the settlement or closing date. For loan originations that an institution acquires through a broker, the institution reports either the settlement or closing date, or the date the institution acquired the loan from the broker. If the disbursement of funds takes place on a date later than the settlement or closing date, the institution may use the date of disbursement.

As long as you are consistent in the date being reported, you would be OK using either the note date, or the disbursement/funding date. I would opine using the note date would be the easiest and most consistent of the options.

First published on 11/15/04

First published on 11/15/2004

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