Small Creditor Exemption

Posted By: CNBAudit

Small Creditor Exemption - 11/07/13 03:15 PM

We have a master loan purchase agreement with several correspondents. We take the application which is underwritten by the correspondents underwriters. We receive a written commitment to purchase at the loan approval and we distribute our funds at closing. We immediately transfer the loan to the correspondent after closing and receive final funding within a few days. Must we count these loans in our 500 or fewer small creditor calculation.
Posted By: rlcarey

Re: Small Creditor Exemption - 11/07/13 03:14 PM

The loans are in your name as the creditor - correct?
Posted By: CNBAudit

Re: Small Creditor Exemption - 11/07/13 03:19 PM

Yes - the loans are originated and funded in our name and then immediately sold
Posted By: rlcarey

Re: Small Creditor Exemption - 11/07/13 03:32 PM

Then they are your loans whether you held them for 10 seconds or two months.