HMDA Action Taken Date
Under Regulation B, when an applicant withdraws an application, there is no requirement to send the applicant a notification. That said, some institutions still choose to do so. If you are a HMDA reporting institution, Regulation C requires you to report the action taken date. So, in the case of a withdrawal, whether you send a notification or not, you need a way to document the date the application was withdrawn. If you don’t send a notification of withdrawal, it might be as simple as the lender making a file comment. If you do send a notification, the action taken date is typically the date on the notification. Similarly, Regulation B doesn’t address applications that are “approved but not accepted”, but Regulation C does. So, again, if you are a HMDA-reporting institution, you need a way to document the action taken date. At the end of the day, you just want to ensure that the action taken date reported on your HMDA LAR can be supported within your file documentation.
David explains more in the video.
Published
2025/03/21
David Dickinson
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.