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.