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#2196524 - 10/25/18 09:51 PM ULI - Exempt but ULI provided to investors
Katherine Offline
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Posts: 62
Have any exempt institutions that sell loans decided whether to drop the ULI? Any thoughts on the matter? Prior to S 2155 being passed, we sold loans to Freddie and provided the ULI as required. My plan was to file the 2018 LAR with the ULI since we already sold loans with a ULI.

However, since we are now exempt, I'm wondering if we should just use our old process (application number since it meets the NULI criteria) and we can just provide a ULI to the investor since they haven't advised us that they do not require one and we have been providing one. However, for consistency purposes, would it be best to follow the ULI and file the LAR with it? Part of the issue is our portfolio loans use a legacy system which cannot calculate the check-digit and instead, I use the CFPB tool to generate the check-digit and then manually paste it into our LAR.

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#2196533 - 10/26/18 12:07 PM Re: ULI - Exempt but ULI provided to investors Katherine
Adam Witmer Offline
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I've been recommending using the ULI if it is automated in your HMDA software as it would just help to avoid future issues with investors. Since you have a manual process, I definitely see your pain. If it were me, I would probably want to be 100% sure they aren't ever going to need the ULI before I change to a NULI. I think that only your investor(s) can answer this question for you, though I will be interested to see if others have heard anything from investors.
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#2196645 - 10/26/18 11:18 PM Re: ULI - Exempt but ULI provided to investors Adam Witmer
Katherine Offline
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Joined: Aug 2017
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Thank you. We will stay the ULI course for now. We haven't received any straight answers we can rely on, so we are sticking with the least risky path.

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#2196682 - 10/29/18 03:22 PM Re: ULI - Exempt but ULI provided to investors Katherine
Dan Persfull Offline
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Bloomington, IN
Why would a partially exempt FI assigning a NULI be an issue for investors? If the investor purchases a loan with NULI the investor is responsible for generating a ULI if they too are not partially exempt.

49 Additionally, if a financial institution that is subject to HMDA and not eligible for a partial exemption purchases a
loan originated by a partially exempt institution that assigned a non-universal loan identifier rather than a ULI, the
purchasing institution does not report the non-universal loan identifier previously assigned. Instead, the purchasing
institution assigns its own ULI because no ULI was assigned by the institution that originated the loan. See
comment 4(a)(1)(i)-3.
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#2196689 - 10/29/18 03:46 PM Re: ULI - Exempt but ULI provided to investors Katherine
Adam Witmer Offline
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In theory, there shouldn't be an issue. That said, investors have been know to have odd demands for their loans and I've heard some discussion about at least one investor that was trying to make a fuss about this. My point was that if the ULI doesn't create any additional work, why not continue to use it? Katherine's situation, however, is a bit different since it is a manual process for them.
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#2197006 - 11/01/18 12:31 AM Re: ULI - Exempt but ULI provided to investors Katherine
SMQ, CRCM Offline

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Between the lines
What is the cost to renew the ULI each year?
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#2197013 - 11/01/18 11:36 AM Re: ULI - Exempt but ULI provided to investors Katherine
RVFlyboy Offline
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You don't renew the ULI. You renew the LEI, which is part of the ULI. And even the partially exempt filers have to still have an LEI.
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#2197014 - 11/01/18 11:43 AM Re: ULI - Exempt but ULI provided to investors SMQ, CRCM
Adam Witmer Offline
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Originally Posted By SMQ, CRCM
What is the cost to renew the ULI each year?

I believe the annual renewal fee was recently reduced so the total cost (with the processing fee) is currently around $100 a year.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2197052 - 11/01/18 03:36 PM Re: ULI - Exempt but ULI provided to investors Adam Witmer
RVFlyboy Offline
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Originally Posted By Adam Witmer
Originally Posted By SMQ, CRCM
What is the cost to renew the ULI each year?

I believe the annual renewal fee was recently reduced so the total cost (with the processing fee) is currently around $100 a year.
Again, I think Adam is referring to the cost to renew the LEI (not the ULI), which ALL HMDA reporters have to have, even with the partial exemption.
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