HMDA data requirements include an application date. What should we consider in reporting this information?

Compliance > Regulation C - HMDA > 2018 Provisions
Q:  HMDA data requirements include an application date.  What should we consider in reporting this information?
 
A:  Except for a purchased Covered Loan, a Financial Institution reports the Application date, which is reported as either the date that the Application was received or the date on the Application form. 12 CFR 1003.4(a)(1)(ii). Although a Financial Institution need not choose the same approach for reporting Application date for its entire HMDA submission, it should be generally consistent, such as by routinely using one approach within a particular division of the Financial Institution or for a category of loans. Comment 4(a)(1)(ii)-1.
 
If a Financial Institution chooses to report the date shown on the Application form and the Financial Institution retains multiple versions of the form, the Financial Institution reports the date shown on the first form it received that constitutes an Application under the 2015 HMDA Rule. Comment 4(a)(1)(ii)-1.
 
For an Application that was not submitted directly to the Financial Institution, the Financial Institution may report the date the Application was received by the party that initially received the Application, the date the Application was received by the Financial Institution, or the date shown on the Application form. Comment 4(a)(1)(ii)-2.
 
If, within the same calendar year, an applicant asks a Financial Institution to reinstate a counteroffer that the applicant previously did not accept (or asks the Financial Institution to reconsider an Application that was denied, withdrawn, or closed for incompleteness), the reportable Application date depends on whether the Financial Institution reports the request as the continuation of the earlier transaction using the earlier transaction’s ULI or as a new transaction with a new ULI. If the Financial Institution treats the request for reinstatement or reconsideration as a new transaction, it reports the date of the request as the Application date. If the Financial Institution does not treat the request for reinstatement or reconsideration as a new transaction, it reports the original Application date. Comment 4(a)(1)(ii)-3.
 
For a purchased Covered Loan, a Financial Institution reports that this data point is not applicable. 12 CFR 1003.4(a)(1)(ii).
 
 
ADDITIONAL INFORMATION:
This information was obtained from the CFPB’s Home Mortgage Disclosure (Regulation C) Small Entity Compliance Guide:  https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201512_cfpb_hmda_small-entity-compliance-guide.pdf

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