HMDA: Action Taken Date
One of the data fields required to be reported for HMDA is the Action Taken Date. While this might seem pretty straightforward, the regulation actually gives you some flexibility in certain instances. For example, if an application is denied or closed for incompleteness, the Regulation states an institution can report … either the date the action was taken or the date the notice was sent to the applicant. Similarly, for an application that is originated, the institution can report …date of the action taken by the financial institution…or the date of initial disbursement. While this flexibility can be helpful in aligning your procedures and processes with your reporting, we do recommend you try to be consistent. You also need to be aware that in some instances you cannot utilize this flexibility.
David explains more in the video.
2025/03/10
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.