HMDA-reportable institutions are required to report …the date the application was received or the date shown on the application form… on its HMDA-LAR. We don’t often get a lot of flexibility when it comes to compliance and so on the surface it seems nice to have options. However, the Commentary to §1003.4(a)(1)(ii) #1 does point out that institutions should generally be consistent in their approach from application to application. Additionally, after many years of reviewing, training and consulting on HMDA, David discusses his preferred method in the video:
Published 2026/10/23