Quick question for the group as I am receiving conflicting information. As a mini-correspondent lender where the Investor is making the credit decision and mini-corr is not, who should be reporting that HMDA information? I have been giving answers each way. One investor states we should as we are the originator and another one since they make the credit decision in the eyes of HMDA reporting they are the originator and should be reporting.

Starting on Page 25 of the new GIR:

TRANSACTIONS INVOLVING MULTIPLE ENTITIES
Only one financial institution reports the origination of a covered loan. If more than one institution is involved in the origination of a covered loan, the institution that makes the credit decision approving the application before loan closing or account opening is responsible for reporting the origination of the covered loan. It is not relevant whether the loan closed in the reporting financial institution’s name. If more than one institution approved an application prior to loan closing or account opening and one of those institutions purchased the covered loan after closing or account opening, the institution that purchased the covered loan after closing or account opening is responsible for reporting the origination of the covered loan. Comment 4(a)-2.i.

It's important to note, however, that if you turn the loan down, or the customer withdraws, while still in the control of your company, you will be the reporter. The above doesn't cover the entire coverage information, but it is discussed further down that page and then gives examples further down.

[Just in case the OP thought that was the entire content of that section]

Those were the answers I thought which is good as I feel like I know something now. Thank you for the feedback.