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Are Subprime Loans HMDA Reportable?
Dan Persfull, BOL Guru
Guru Bios
Question: We recently began to offer "subprime" lending. Our internal compliance officer is indicating that our subprime loans are not HMDA reportable because the investors we are working with "make the credit decision". If we are originating the loan and the loan meets one of the three requirements of HMDA, how is it that we would not have to report these strictly based upon who is underwriting the loan?
Answer: Your compliance officer is correct. The financial institution that makes the credit decision reports the loan for HMDA purposes. You'll find this information in the "Getting it Right" guidelines beginning on page 6.
First published on BankersOnline.com 6/19/06
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