Clearly, you aren't making the loan without at least an estimate of value, whether it's the purchase price, a value provided by FNMA (see Truffle Royale's post ^^^) or an in-house estimate. Without it, you could not responsibly make the loan. Whatever value that is is what HMDA requires you to report.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8