All,

Question on a correspondent loan. We made a credit decision on the correspondent loan that we underwrite but they close the loan in their name (with their doc provider). In the past we would report the loan as a loan originated (since we made the credit decision) or denied (even if the loan originated but we chose not to purchase it for XYZ reason). With ULI's now in place, I would assume that I would just need the ULI they assigned using their LEI or is that incorrect. In essence, then the correspondent would have the ULI on their LAR showing loan originated and I would show the ULI on my LAR as loan denied?

An application is either approved or denied - how can it be both?

Obviously I'm not explaining this scenario well enough.

Hopefully this will explain it better.


Correspondent Lender received an application for a covered loan from an applicant and forwarded that application our bank. Our bank reviewed the application and approved the loan prior to closing. The loan closed in Financial Institution A's name. Our bank then denied the loan from correspondent lender after closing due to issue at closing. Our bank was not acting as corresponding lender's agent. Since our bank made the credit decision prior to closing, our bank reports the transaction as a denial.

Would we report the loan using the correspondent lender's ULI (if they assigned one at closing using their own LEI, loan number & check digit) or our own ULI (since we made a credit decision)?

No, you didn't deny the loan. You just refused to purchase it. What you do AFTER closing does not change the fact that you approved the application and the loan actually closed.

You use your ULI to report this just like you do on all your other loans.