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#1806523 - 04/19/13 05:05 PM HMDA and Purchase Codes
MSB05MS Offline
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I am wondering how others might be reporting mortgage loans sold secondary, we make the credit decision not the purhcaser. I have how examiners advised reporting purchaser codes documented and then our consulting group disagreed with some of these codes.
Franklin American Mortgage Company - code 9
Wells Fargo Funding, Inc (show on correspondent purchase agreement)yet the lock agreements has Wells Fargo Home Mortgage a division of Wells Fargo Bank, N. A. Is this a code 6?
Suntrust Mortgage, Inc.(show on correspondent purchase agreement), yet I find on web-site as a registered service mark of Suntrust Banks, Inc. Code 7 or 6?
Just want another opinion.

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#1806529 - 04/19/13 05:17 PM Re: HMDA and Purchase Codes MSB05MS
Truffle Royale Offline

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We report Sun as a 7.
Will be using Franklin soon.
My post here has links to the NIC site my FRB examiners directed me to use for purchaser codes.
Personally, I wouldn't worry about what your consulting group is saying unless they've got documentation to back up where they're getting their info from and why they're using it.

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#1806642 - 04/19/13 07:27 PM Re: HMDA and Purchase Codes MSB05MS
MSB05MS Offline
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I have it from notes with FDIC examiers Franklin Mortgage is a 9, not a 7 becasue they are NOT a mortgage bank but a mortgage company.
Thanks for your input on SunTrust, we should be good on it.

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#1891451 - 01/28/14 10:13 PM Re: HMDA and Purchase Codes MSB05MS
Colorado Girl Offline
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Using the link above for the NIC site, I have several investors with results of 'Domestic Entity Other' - Domestic institutions that engage in banking activities usually in connection with the business of banking in the United States.
How does this fall into Purchaser Codes for HMDA?

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#1891455 - 01/28/14 10:20 PM Re: HMDA and Purchase Codes MSB05MS
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Define mortgage bank vs mortgage company?
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#1891471 - 01/28/14 10:57 PM Re: HMDA and Purchase Codes MSB05MS
Colorado Girl Offline
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Joined: Mar 2013
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We use SunTrust Mortgage, Inc. headquartered in Richmond, Virginia and Franklin American Mortgage headquartered in Franklin, Tennessee. Using the NIC website, it tells me that they are both 'Domestic Entity Other'. In fact, that site doesn't specify Mortgage Company or Mortgage Bank.

The individual who manages our investor relations hasn't ever asked what the investors Purchaser Code was and when I took over the analysis of the HMDA data this year I realized that we have always coded all sold loans as a code 7. I didn't question it because I was told that all our investors are code 7 when I was being taught (until I noticed we sell to JP Morgan and U.S Bank too) so I'm left trying to figure it out. I'm wondering how the above site helps determine 'Other' versus 'Mortgage Bank' or 'Mortgage Company' without it being specified in the name. Should I ask to look to the contracts we have with the investors? Or just call them? Please advise!

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#1891666 - 01/29/14 04:38 PM Re: HMDA and Purchase Codes Colorado Girl
sapaudit Offline
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We had to resubmit 2011/2012 LAR's because we were coding our secondary market purchasers as all 7's. Sometime in 2011 we started selling to a company the regulator's said was a 6. I would check your purchasers very carefully.

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#1891675 - 01/29/14 04:53 PM Re: HMDA and Purchase Codes MSB05MS
Colorado Girl Offline
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Posts: 67
That's exactly what I didn't want to hear!! smile

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#1891730 - 01/29/14 06:30 PM Re: HMDA and Purchase Codes MSB05MS
Truffle Royale Offline

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I've been dinged on info received from investors too.
I still use the NIC site as the basis for my answers.
Franklin came up on my NIC search as a 'Non-deposit Trust Company'.
I have it from a good authority that Franklin should be coded a 7 but I hadn't thought of using 9.
There's still time to change my Franklins to a 9 if that turns out to be the consensus (with good logical backing) here.

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#1892412 - 01/31/14 07:23 AM Re: HMDA and Purchase Codes MSB05MS
Kathleen O. Blanchard Offline

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Some of them tell you in their guide how to code the loans they purchase. I think it is SunTrust that tells you to use 7, which I agree with. Itis not the bank itself buying the loan but an affiliate, a subsidiary of the bank.

Sometimes things change. I believe it is Wells that used to be a 7 but now it is the bank itself buying. Those contracts and investor guides are important. What legal entity is buying the loan?

I consider Franklin American Mortgage Company to be a 7.

https://franklinamerican.com/ext/general?npage=aboutUs

Franklin American Trust is not to my knowledge the same company. It is listed by the Fed on the NIC site as inactive.

NIC does not necessarily list every investor. "About the National Information Center (NIC)

The National Information Center (NIC) provides comprehensive information on banks and other institutions for which the Federal Reserve has a supervisory, regulatory, or research interest including both domestic and foreign banking organizations operating in the U.S."

The banking institutions coded as "6" are deposit taking institutions. Enter commercial bank as entity type and choose a city name and see what you get. You,will see what I mean. Same with savings banks and savings and loans.




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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2128470 - 04/28/17 11:41 PM Re: HMDA and Purchase Codes Kathleen O. Blanchard
Darth HMDA, CRCM, CAMS Offline
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Originally Posted By Kathleen B
Define mortgage bank vs mortgage company?



What is the answer to this question for HMDA Purchaser coding purposes?
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