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#1992652 - 01/30/15 09:32 PM HMDA & "loan" repurchase
Red Raiders Offline
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Red Raiders
Joined: May 2013
Posts: 1,069
Compliance Land
Strange scenario:

Our investor foreclosed on a loan we were servicing (and originated) and in looking at the underwriting we did determined we had to purchase the loan back. This property was already in their OREO and we cut them a check for the amount of what would have been outstanding on the loan and put the property in our OREO.

This doesn't count as a loan purchase for HMDA does it? The loan doesn't really exist anymore as the property was/is is OREO and the borrower filed BK.
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#1992675 - 01/30/15 09:57 PM Re: HMDA & "loan" repurchase Red Raiders
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Was sale and repurchase in same calendar? That eliminates purchase. If a subsequent year, it is a purchase.
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HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
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#1992680 - 01/30/15 10:10 PM Re: HMDA & "loan" repurchase Red Raiders
Red Raiders Offline
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Red Raiders
Joined: May 2013
Posts: 1,069
Compliance Land
Origination was in 2013, repurchase of property was in 2014.

So you are saying this is a reportable loan purchase? I guess I had it in my head that the loan is no more since the investor had the loan in OREO and we never re-booked it as a loan and put it straight to our OREO.
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#1992710 - 01/31/15 02:08 AM Re: HMDA & "loan" repurchase Red Raiders
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Well, if that is the case, then you have to determine what you have. You bought back a property, not a loan? Then not HMDA reportable.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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