We've had a question come up that we can't definitively answer. If a mortgage loan is not originated; however we know that it would be initially payable to our institution (they all are) should we use a code '1' or a code '3'? From my reading of the regulation and the FIG I believe we should use the code '1'.

Thank you!

Section 1003.4(a)(33)(ii) requires financial institutions to report whether the obligation arising from a covered loan was or, in the case of an application, would have been initially payable to the institution.

For what it's worth - we report all with code '1' as all of ours are also initially payable to our institution. We just completed a data integrity review which included 2018 data and our exam team agreed.

That's not true for everyone, though.

Thank you for confirming our thoughts, Joker and Island. It's always nice to have backup!!