Can someone please direct me on how to report a purchased loan. We have bought a loan back from Freddie Mac. What would the purpose be? The same purpose as whent he loan was made originally?

Yes, the purpose is the same. The action code is 6, purchased. For amount, follow the instructions in Appendix A to Reg C:

http://www.bankersonline.com/regs/12-1003/12-1003-000.html#appa

Go through Appendix A for proper completion of each field.

What about income? Use what was previously used or NA? And GMI..what was originally on the application..or 4 and 7...? And, type of purchaser? Since we had to buy it back (portfolio loan), would we still use 0?

Follow the rules, paying attention to special instructions for purchased loans. Type of purchaser is 0. You are not selling, you are buying.

Agree with Kaybee. Treat the loan as if you had not originated it and it is strictly a purchase.

Regarding GMI:

(b) Collection of data on ethnicity, race, sex, and income. (1) A financial institution shall collect data about the ethnicity, race, and sex of the applicant or borrower as prescribed in appendix B of this part.
(2) Ethnicity, race, sex, and income data may but need not be collected for loans purchased by the financial institution.

This is also supported in Appendix B:

1. Applicability. Report this information for loans that you originate as well as for applications that do not result in an origination.
a. You need not collect or report this information for loans purchased. If you choose not to report this information, use the Codes for “not applicable.”



We always take the stance, if you don't have to report it... don't report it.

Also, if the loan was repurchased in the same year that it originated, it will not be reported a second time. If that is the case, simply remove the type of purchaser on the original loan.

Thanks, hmdagal. That is a very important point to remember. If the purchase/buyback is in a subsequent year, the purchase rules become applicable, in the same year the loan is simply not reported as purchased.

"Also, if the loan was repurchased in the same year that it originated, it will not be reported a second time. If that is the case, simply remove the type of purchaser on the original loan."....so CHANGE the purchaser type to "6" - loan purchased?

The type of purchaser will be '0' - loan not originated or sold in the current year. The action type will be '1' - loan originated.

I would like to add to this existing topic. I am under FRB exam, and we have been purchasing mortgage loans. I am just finding out that I was to report the loan amount at the time of the purchase and not the note amount.

This makes sense, but I don;t see any instruction to so so within Getting it Right. Can someone direct me to this in the reg or related materials? Thank you!

Oops - found it already under Appendix A Comment 7 b - darn it! Hope someone else can learn from my error. Thanks

Comment 7b says "b. For a home purchase loan that you purchased, enter the unpaid principal balance of the loan at the time of purchase."

What if you purchased a refinance back? Would you report the original loan amount, or the unpaid principal at the time of purchase?

A loan was closed as a VA loan but the investor does not purchase it due to some problem with the documentation. Since we kept it as a portfolio loan, the VA fee was refunded to the customer after the loan closed. I know that we report it as having no purchaser, but do we continue to report it as a VA loan, which it closed as, or report it as a Conventional loan since we refunded the fee and have it in portfolio?

It is staying in your portfolio and you do not do VA loans, change the loan type to conventional.

If the loan is not guaranteed by the VA, it is not reported as a VA loan. It would have to be conventional.

Thanks for the responses. I wasn't sure if it was reported based on what the customer thought it was or how it ended up.

As stated above, for a purchased loan, " You need not collect or report this information for loans purchased. If you choose not to report this information, use the Codes for NOT APPLICABLE." If our purchased loan has an applicant but NO co-applicant, would we use the codes for "No co-applicant" rather than "Not Applicable"? Or would we use "Not Applicable" for both?

If you have no co applicant, you report the codes for no co applicant, not the codes for Not Applicable.

For example, for GMI, you would report 5 8 5 and not 4 7 4 if you have no co applicant.

Thank you!

Is this statement still accurate under the new HMDA rules for 2018 and beyond? Is there a citation for this?

It looks like it goes away. From the final rule (pg 173):

The Bureau has determined that repurchases of covered loans should be reported as loan
purchases, with only a narrow exception discussed below. The Bureau believes that the one-calendar-
year reporting exception, which was based on guidance originally published by the
FFIEC, will no longer be needed in light of other elements of the final rule.