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Let's go to page 60. So now not only do we need to report what the action was, we report when it happened. And it says at the very top that there's some leniency, that you have some leeway if you will. And that's true, but look at the letter E, letter E at the very bottom of page 60. If you cross over a year, you don't have the flexibility. What do I mean by that? Well, if you have a loan that is rescindable, very top, number 11, you can go with the loan date, which I highly recommend or you can go with the day you advanced the funds, which I don't recommend. But if you closed a loan on December 29th and you're advancing it on January 3rd, you cannot go with January 3rd. You have to go on December 29th because it crossed over a year and HMDA is calendar year driven.
So it's the date in the year that it happened. We can't allow it to cross over. If you go down to letter D, construction to perm. So now you're going to report the day that it converts to permit financing. Not if it crosses over a year, which most construction loans are 9 to 12 months anyway, so most of them are going to cross over a year. I have highly recommend that you always go with the day on the loan. The examiner can look at that, they can look at the LAR, and go, yep and they're done. If you go with any subsequent date, they have to dig and it's wasting your time and their time, and they are there longer than they need to be.
