We originate several commercial purpose loans that are subject to HMDA (rehab/rental; rehab/resell). These are typically large organizations we borrow to and sometimes we will run into a legal lending limit issues so we have to participate or sell the loan to one of our affiliate banks.
In reading the GIR, if the lead bank keeps over 50% of the loan, we would not report a purchaser code. However, if we sold more than 50% to one of our affiliates, I would have to report that purchaser code on my LAR correct?
And if I report it on my lead bank LAR, even if we sell 100%, we only report it on the lead bank, not on the purchasers LAR, RIGHT?