In the last exam we got credit for loans that went secondary market that were for affordable housing like FSA, Home Ready etc. HMDA was done by the other mortgage companies as they did the underwriting. If we started doing the underwriting meaning we would have to do the HMDA would that no longer qualify as a CD loan?

That is correct, depending on your size--you may be able to choose which loans to report where. Not knowing anything beyond your question I'd consult the Interagency Q&As to see.

Thank you!