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#2218560 - 07/26/19 06:28 PM Repurchased Loans
MyThirdLogin Offline
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Joined: May 2019
Posts: 27
If a loan is originated in the same year that a repurchase occurs, would we report the record twice? once as an origination and once as repurchased?

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#2218567 - 07/26/19 07:37 PM Re: Repurchased Loans MyThirdLogin
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
A purchase includes a repurchase of a covered loan, regardless of whether the financial institution chose to repurchase the covered loan or was required to repurchase it because of a contractual obligation and regardless of whether the repurchase occurred within the same calendar year that the covered loan was originated or in a different calendar year. Comment 4(a)-5.
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#2218750 - 07/30/19 04:38 PM Re: Repurchased Loans MyThirdLogin
MyThirdLogin Offline
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Joined: May 2019
Posts: 27
awesome - thanks.

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#2219665 - 08/13/19 08:41 PM Re: Repurchased Loans MyThirdLogin
MyThirdLogin Offline
Junior Member
Joined: May 2019
Posts: 27
as I continue to read this, I still do not know how to report a repurchase and I cannot find comment 4(a)-5. Is it 1 record or 2 records on the LAR? I don't think this is clear - not that I expect it to be clear - but I am not sure how other do this.

thanks.

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#2219666 - 08/13/19 08:53 PM Re: Repurchased Loans MyThirdLogin
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,842
2 records.

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#2219760 - 08/15/19 12:33 PM Re: Repurchased Loans MyThirdLogin
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
https://www.bankersonline.com/regulations/12-1003-004

5. Purchased loans. i. A financial institution is required to collect data regarding covered loans it purchases. For purposes of § 1003.4(a), a purchase includes a repurchase of a covered loan, regardless of whether the institution chose to repurchase the covered loan or was required to repurchase the covered loan because of a contractual obligation and regardless of whether the repurchase occurs within the same calendar year that the covered loan was originated or in a different calendar year. For example, assume that Financial Institution A originates or purchases a covered loan and then sells it to Financial Institution B, who later requires Financial Institution A to repurchase the covered loan pursuant to the relevant contractual obligations. Financial Institution B reports the purchase from Financial Institution A, assuming it is a financial institution as defined under § 1003.2(g). Financial Institution A reports the repurchase from Financial Institution B as a purchase.
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