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We are in the middle of a HMDA scrub for 2015 on a bank we acquired, and I’d like to know what you would do in this situation. It appears their practice on what date to use for action taken on loans originated, was to use the date of the promissory note. Frequently the date of closing, settlement is later thant that. Would you change those dates to the actual closing date, or leave it as is as they were consistent.
I would leave it as is since they were consistently using the date of the promissory note. That is what we have been told in past audits regarding action taken date, what date we use is up to us as long as we are consistent with it.
The instructions for completing the LAR that for a loan that is originated the date of action taken should be the date settled or closed, or the date funds are disbursed. I agree with the comment regarding consistency, but being consistently wrong is not a good thing. If the date of the promissory note is a date other than the date settled or closed, or the date funds are disbursed, then a correction is appropriate.
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