If a bank knows that the third party where the loans were purchased from, is reporting (HMDA)these loans, is the bank required to report as well? I seem to remember somewhere in the regulation, that HMDA data should not be reported by both.
The entity that makes the credit decision reports the loan as an origination and if the loan is purchased by another entity they report it as a purchased loan.
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The opinions expressed are mine and they are not to be taken as legal advice.