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#1869264 - 11/07/13 10:15 AM Small Creditor Exemption
CNBAudit Offline
New Poster

Registered: 11/07/13
Posts: 3
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.

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Ability to Repay/Qualified Mortgage Rule Forum
#1869266 - 11/07/13 10:14 AM Re: Small Creditor Exemption [Re: CNBAudit]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49446
Loc: Galveston, TX
The loans are in your name as the creditor - correct?
_________________________
The opinions expressed are my own, take them or leave them.

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#1869271 - 11/07/13 10:19 AM Re: Small Creditor Exemption [Re: CNBAudit]
CNBAudit Offline
New Poster

Registered: 11/07/13
Posts: 3
Yes - the loans are originated and funded in our name and then immediately sold

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#1869286 - 11/07/13 10:32 AM Re: Small Creditor Exemption [Re: CNBAudit]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49446
Loc: Galveston, TX
Then they are your loans whether you held them for 10 seconds or two months.
_________________________
The opinions expressed are my own, take them or leave them.

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