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#472126 - 12/19/05 06:32 PM Preapproval Codes
tumbleweed Offline
Member
Joined: Apr 2004
Posts: 86
Michigan
If your bank has a preapproval program under the mortgage department, however do not under the consumer credit department. Can you report all consumer loans as preapproval code "3"? The LARS will be combined at year end for submission.
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#472127 - 12/19/05 06:37 PM Re: Preapproval Codes
RR Becca Offline
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RR Becca
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
I don't know how correct it is, but that is how I report ours. Our consumer credit dept has no formal preapproval program, only our secondary market mortgage dept does.

Hopefully one of the gurus will chime in here and say this method is appropriate. FWIW - it passed our last exam without so much as a raised eyebrow.
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#472128 - 12/19/05 06:39 PM Re: Preapproval Codes
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
This is a trick question. No, you cannot report all consumer loans as a code 3. The consumer loans booked through your mortgage department, for home purchase transactions, would be reported either as a 1 or 2. All consumer loans booked through your consumer loan department can be coded as a 3.

You can have a pre-approval program for one business unit and not another.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#472129 - 12/19/05 06:45 PM Re: Preapproval Codes
RR Becca Offline
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RR Becca
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
LOL! So we're splitting hairs now? Let me re-phrase:

All HMDA reportable loans coming through our secondary market mortgage department, which has a formal preapproval program, are coded 1 or 2 as appropriate.

All HMDA reportable loans coming through our regular loan department (both consumer and commercial), which does not have a formal preapproval program, are coded 3.

Is this better, Dan? This stuff makes my head spin....

edited to add: After re-reading this, I realize my tone comes across as snarky and I apologize. Of course we're splitting hairs - this is compliance, and I should know better by now than to speak in generalities. At least the complexity grants us some measure of job security, eh?
Last edited by Becca; 12/19/05 06:52 PM.
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#472130 - 12/19/05 07:46 PM Re: Preapproval Codes
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Quote:

All HMDA reportable loans coming through our secondary market mortgage department, which has a formal preapproval program, are coded 1 or 2 as appropriate.


All HMDA reportable loans coming through our regular loan department (both consumer and commercial), which does not have a formal preapproval program, are coded 3.




That's correct.

I wasn't trying to split hairs (I knew what you were referring to ), I was just trying to add a little humor to a dull regulation.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#472131 - 12/19/05 09:27 PM Re: Preapproval Codes
Moman Offline
Platinum Poster
Joined: Jul 2004
Posts: 505
WA
Bah - HMDA!

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#472132 - 12/19/05 09:33 PM Re: Preapproval Codes
Glo Offline
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Joined: Jul 2005
Posts: 394
Arkansas
LOL!!! That was clever!

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#472133 - 12/19/05 09:56 PM Re: Preapproval Codes
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Quote:

Bah - HMDA!




_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#472134 - 12/19/05 09:57 PM Re: Preapproval Codes
RR Becca Offline
Power Poster
RR Becca
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
Quote:

That's correct.

I wasn't trying to split hairs (I knew what you were referring to ), I was just trying to add a little humor to a dull regulation.




Yep. Mine was a sad Monday attempt at sarcasm.

Quote:

Bah! HMDA!




LOL! May I borrow that for my email signature until after the 1st of the year?
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You call it ADD. I call it multi-tasking.

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