Top Violations: Application Date
There really isn’t a regulatory requirement to document the application date within your loan file. However, it is so important! The “application date” often triggers a wide range of compliance requirements and disclosures. And, in the case of HMDA, you must report it on your HMDA-LAR. If you don’t document the application date somewhere, chances are you will have a hard time proving whether you got disclosures out within required timeframes or reported the correct date. You also have to be aware that there can be multiple application dates. Some regulations define an “application” differently than others. So, for instance, the application date for Regulation B requirements/disclosures may or may not be the same as for Regulation Z requirements/disclosures. Confusing the two could lead to violations.
Kevin explains more in the video.
2024/11/18
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).