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
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!