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#2113581 - 01/09/17 09:56 PM
Re: Loan Entity Identifier
Truffle Royale
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Gold Star
Joined: Sep 2016
Posts: 351
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Kathleen - a couple of questions regarding the LEI 1. Are all HMDA reporting Financial Institutions required to have an assigned LEI for 2018 reporting and beyond? 2. If my institution is currently not required to report as we meet all tests (asset size, volume, etc) should we still apply for the LEI and have it in case we do have a year where we have to report?
Thank you.
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#2114216 - 01/13/17 05:29 PM
Re: Loan Entity Identifier
crcmnot
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Gold Star
Joined: Sep 2016
Posts: 351
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Kathleen - a couple of questions regarding the LEI 1. Are all HMDA reporting Financial Institutions required to have an assigned LEI for 2018 reporting and beyond? 2. If my institution is currently not required to report as we meet all tests (asset size, volume, etc) should we still apply for the LEI and have it in case we do have a year where we have to report?
Thank you. Reviving this questions so it doesn't get lost.
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#2116155 - 01/30/17 10:31 PM
Re: Loan Entity Identifier
Kathleen O. Blanchard
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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We are a unitary bank holding company. The parent (holding company) already has a LEI. Only the bank makes loans. Would the bank need to apply for a separate LEI, or can we use the Bancorp's?
_________________________
Management is doing things right; leadership is doing the right things. Peter Drucker
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#2116178 - 01/31/17 01:02 PM
Re: Loan Entity Identifier
David Dickinson
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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Thanks, David. I couldn't find anything in the regulatory text, or the Official Interpretation, or in the Section-by-Section analysis, either.
_________________________
Management is doing things right; leadership is doing the right things. Peter Drucker
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#2116378 - 01/31/17 09:52 PM
Re: Loan Entity Identifier
Kathleen O. Blanchard
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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Thanks, Kathleen. I was afraid that was going to be the answer. HMDA 2018 just seems like a windfall for the GMEI Utility.
_________________________
Management is doing things right; leadership is doing the right things. Peter Drucker
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#2117096 - 02/06/17 03:32 PM
Re: Loan Entity Identifier
Truffle Royale
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100 Club
Joined: Jul 2014
Posts: 194
MO
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So am I understanding that even if we have always been a HMDA reporting FI, I will still have to get a LEI for us?
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#2117121 - 02/06/17 05:12 PM
Re: Loan Entity Identifier
Truffle Royale
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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Yes, you will need the LEI.
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2121189 - 03/08/17 11:43 PM
Re: Loan Entity Identifier
Truffle Royale
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Member
Joined: Jun 2011
Posts: 82
Oregon
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I am reading "covered transactions" need to include ULI included on applications and certain documents. If we are not a covered institution because we have not met the transaction thresholds in each of the prior two years, do we need to obtain the ULI just to have the # on our documents?
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#2121575 - 03/10/17 08:38 PM
Re: Loan Entity Identifier
Truffle Royale
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Gold Star
Joined: Jan 2010
Posts: 293
Oklahoma
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@ Kake ... where are you finding that we have to include the ULI on application forms and other documents? I hope we do not have to do so. Thanks!
_________________________
Compliance - A Painful Addiction
All comments are mine & should not be taken as legal advice.
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#2121613 - 03/11/17 12:17 AM
Re: Loan Entity Identifier
Truffle Royale
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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There is not a requirement to put the ULI on the application. It is an option on the updated URLA when released but I don't know if it will fit 45 characters.
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2126162 - 04/13/17 01:43 PM
Re: Loan Entity Identifier
Truffle Royale
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100 Club
Joined: Sep 2005
Posts: 159
Midwest
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Which organization did you all use to obtain the LEI? Is there any US companies that issue the LEI? The list I looked at appears to have only foreign companies.
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