We originate DPA 2nd mortgages with simultaneous 1st mortgages. We've got 1st mortgages that are underwritten with TOTAL and include the amounts for the 2nd when running TOTAL. We would not allow the DPA 2nd to be originated if TOTAL does not come back as 'Accept' at the CLTV % that would include the 2nd. Feels odd marking a conventional loan with TOTAL and Accept for HMDA but there are no validity errors or anything from doing it that way and it makes sense to me as we are basing our decision on that information. Any thoughts or opinions on reporting it that way?

Bump

We report these using the codes from the 1st loan, since that is what we relied on in making our loan. There isn't clear guidance on this topic that I have found, so we picked a way to report that seemed reasonable and will do it that way until we are told otherwise.