I want to be sure I have this straight, as we have a non-HMDA-reporting affiliate that we often sell loans to and purchase loans from under a participation agreement. If some of these credits are HMDA-reportable, I'd like to give our commercial department a clue in advance. Please feel free to poke holes:

If we underwrite and we originate, report as an origination. (GIR D-1, #2)

If the affiliate underwrites & originates, and we independently underwrite (as part of our purchase decision); and then we decide to purchase the loan, report as an origination. (GIR D-2, #7) (I assume we also report code 3 if we decline to purchase, or code 5 if we agree to purchase but the deal goes south before we book it?)

If the affiliate underwrites and we do not, and we purchase a FULL interest in the loan through a participation agreement, report as a purchased loan, action taken code 6. (GIR D-11, 4(a)(8) #3)

If the affiliate underwrites, and we either do or do not subsequently underwrite as well, and we purchase a PARTIAL interest under a participation agreement, do not report. (GIR D-2, #8)

Thanks in advance -

If we underwrite and we originate, report as an origination. (GIR D-1, #2)

Agree

If the affiliate underwrites & originates, and we independently underwrite (as part of our purchase decision); and then we decide to purchase the loan, report as an origination. (GIR D-2, #7) (I assume we also report code 3 if we decline to purchase, or code 5 if we agree to purchase but the deal goes south before we book it?)

This depends on when you underwrite the loan. If prior to loan closing, then I agree, if after, then you report as purchased any loan you purchase and do not report any loan you choose not to purchase
If the affiliate underwrites and we do not, and we purchase a FULL interest in the loan through a participation agreement, report as a purchased loan, action taken code 6. (GIR D-11, 4(a)(8) #3)

I agree, I think. I assume that purchase of a full interest is not considered a participation, regardless of what type of document is used.
If the affiliate underwrites, and we either do or do not subsequently underwrite as well, and we purchase a PARTIAL interest under a participation agreement, do not report. (GIR D-2, #8)
I agree.
Thanks in advance -

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If we underwrite and we originate, report as an origination. (GIR D-1, #2)

Agree

If the affiliate underwrites & originates, and we independently underwrite (as part of our purchase decision); and then we decide to purchase the loan, report as an origination. (GIR D-2, #7) (I assume we also report code 3 if we decline to purchase, or code 5 if we agree to purchase but the deal goes south before we book it?)

This depends on when you underwrite the loan. If prior to loan closing, then I agree, if after, then you report as purchased any loan you purchase and do not report any loan you choose not to purchase

If the affiliate underwrites and we do not, and we purchase a FULL interest in the loan through a participation agreement, report as a purchased loan, action taken code 6. (GIR D-11, 4(a)(8) #3)

I agree, I think. I assume that purchase of a full interest is not considered a participation, regardless of what type of document is used.

If the affiliate underwrites, and we either do or do not subsequently underwrite as well, and we purchase a PARTIAL interest under a participation agreement, do not report. (GIR D-2, #8)

I agree.

I think I've got it - thanks for the clarification!