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#1837305 - 07/29/13 04:41 PM Who is resaponsible for reporting HMDA
dog1 Offline
Member
Joined: Apr 2013
Posts: 54
Bucks Cnty, PA
Our institution takes the application, pull credit and issue the initial disclosures. (1) We broker the loan to another institution they do underwriting who is responsible for reporting on the LAR. (2) Same circumstances except the broker bank does the underwriting.

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#1837313 - 07/29/13 04:54 PM Re: Who is resaponsible for reporting HMDA dog1
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,858
Bloomington, IN
http://www.ffiec.gov/hmda/guide.htm

Brokered or Correspondent Loans: Who Reports?
When a covered institution makes a loan through a third party such as a broker, the institution, rather than the third party, reports the loan if the institution makes the credit decision. Data on loan applications that do not result in an origination must also be reported by the entity that makes the credit decision. Consult comments 1003.1(c)-2 through -7 (Appendix D to this Guide) for more guidance.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1877656 - 12/11/13 03:02 PM Re: Who is resaponsible for reporting HMDA dog1
lamello2001 Offline
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lamello2001
Joined: Apr 2012
Posts: 59
North Carolina
Who reports if the borrower withdraws the application prior to the credit decision?

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#1877667 - 12/11/13 03:29 PM Re: Who is resaponsible for reporting HMDA dog1
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,351
If the application never made it to the entity that would make the credit decision, then the bank that took the application would be responsible for reporting it as withdrawn.

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#1877725 - 12/11/13 05:05 PM Re: Who is resaponsible for reporting HMDA dog1
lamello2001 Offline
Member
lamello2001
Joined: Apr 2012
Posts: 59
North Carolina
That's what I thought, thanks!

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