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#2231896 - 02/27/20 04:07 PM Purchased and Repurchased in 2019
HMDA Warrior Offline
Junior Member
Joined: Jan 2018
Posts: 48
I have a question about reporting Purchased loans. If a loan was purchased in Q2, sold to another investor and then Repurchased in Q4, do we report both or only the most recent purchase?

I know that if we Originate the loan, sell it to an investor, and then Repurchase the loan within the same year we report the Origination and the Repurchase as 2 entries on the LAR. I wasn't sure if Purchasing a loan and then Repurchasing the same loan would also be reported this way.

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#2231941 - 02/27/20 07:04 PM Re: Purchased and Repurchased in 2019 HMDA Warrior
TomS Offline
Gold Star
Joined: Jan 2004
Posts: 315
USA
I couldn't find in the HMDA Guide where this situation was specifically addressed, but IMO you would report both transactions, since they were separate purchases.
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#2231947 - 02/27/20 07:28 PM Re: Purchased and Repurchased in 2019 HMDA Warrior
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,761
Bloomington, IN
Beginning on page I-26 of the 2020 GIR

5. Purchased loans.
i. A financial institution is required to collect data regarding covered loans it purchases. For
purposes of ยง 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 . . . . .


Search the GIR using repurchase as the search term.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2231955 - 02/27/20 08:29 PM Re: Purchased and Repurchased in 2019 HMDA Warrior
HMDA Warrior Offline
Junior Member
Joined: Jan 2018
Posts: 48
I've also come to the conclusion that we would report both transactions.

I researched the 2019 GIR and didn't feel like the section really addressed the scenario of a purchased loan that was repurchased, but I'll take a look at the 2020 version as well.

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