We originated a fixed-rate loan and sold 100% to another bank, who in turn sold us back 90% at a variable rate. This was all done so that all parties were happy with the rate. On my LAR, I have two loans listed, one originated and one purchased, both for the same amount. Is this double counting when in fact there was only one loan made to the customer? Do I report both the origination and the purchase? If not, which one do I report?

You would report both one as an origination and then as a purchase.

HMDA / CRA - So it is written so it shall be done

The only issue the examiners would have is if they see a lot of this type of transaction and they see it as a way to boost loan numbers to LMI.