On our secondary market loans, we use delegated underwriting so we do not report approvals for HMDA. However, if we pull credit and know the credit score will not qualify for secondary market, we will not run through DU and deny the loan in-house - and report the denial for HMDA.

Is the process correct?

That is what we do as well. Because it's spelled out in our agreement with our correspondent bank, our examiners have had no issues with it.

Thanks!

Can you expand on what you mean by 'use delegated underwriting', beegee?
We use it here and also do the final underwriting on the loans and absolutely report them for HMDA.

Our secondary market investor will actually make the credit decision. Since they make the credit decision - they will report the HMDA.

So you run DU as a filter before sending the loan on to the investor, got it.
fwiw, I agree that you would report any denials you do based on the CBR and DU.
I assume you're reporting withdrawals too.

We do the same thing.

Just to clarify for future readers, beegee's bank is making the underwriting decision to deny the loan and not forward it to their investor based on the results of pulling the credit report and/or running DU.