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#2191746 - 09/06/18 01:55 PM 'Initially Payable to Institution'
Skittles Online
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Skittles
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TN
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!
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#2191752 - 09/06/18 02:08 PM Re: 'Initially Payable to Institution' Skittles
RR Joker Offline
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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.
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#2191753 - 09/06/18 02:10 PM Re: 'Initially Payable to Institution' Skittles
Island Dreaming Offline
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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.
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#2191754 - 09/06/18 02:11 PM Re: 'Initially Payable to Institution' Skittles
RR Joker Offline
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That's not true for everyone, though. wink
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#2191755 - 09/06/18 02:14 PM Re: 'Initially Payable to Institution' Skittles
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Thank you for confirming our thoughts, Joker and Island. It's always nice to have backup!!
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