Loan Application Dates

A loan application date triggers a variety of compliance requirements and getting it right is very important.  While that seems like it would be easy to do, we find that often isn’t the case.  Regulation B (ECOA), Regulation C (HMDA), and TRID each have their own definitions of “application”.  For example, under Regulation B, you have an application when you have a request for credit.  Under Regulation C, you need a request for credit and a property address.  For TRID, you have an application when you receive six pieces of required information (name, income, SSN, property address, property value estimate, and loan amount).  Thus, it’s quite possible to have three different “application” dates for the same loan application!  You need to make sure you are using the correct date for whichever compliance requirements you’re working with.

Want to learn more?  Join us for our Applicants & Applications Webinar.

Also check out our TRID compliance page for an overview of this bank regulation and how you can get training today. 

Listen to Dave explain more.

Published
2018/02/21
Deb Irving

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.

Recent Posts

Advertising: Closed-End Credit Triggering Terms

Mortgage Life Cycle: Requiring Signatures

Complaints: Monitoring, Reporting & Oversight