My company does not lend money or make the lending decision. We provide commercial lending services including loan officers, underwriting, closing and servicing; but all decision making and funding come from the financial institution. As the loan is closed in the institutions name as lender, they are responsible for reporting, but all (most) pertinent information regarding the loan is in my company's possession. Hence, we provide the commercial loan HMDA information to the lending institution to report.
Expect the worst, hope for the best and you'll never be disappointed.