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.