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#2249756 - 02/25/21 02:30 PM Purchased Covered Loan - Loan Costs
wblewis935 Offline
Member
Joined: Feb 2011
Posts: 53
We are purchasing some HMDA reportable mortgage loans. The applications were received by the selling institution in April 2017. They did not report fields like total loan costs, Lender Credits, Discount Points, etc. because it wasn't a required field in 2017. The question I am looking for clarity on is this; we DO report the aforementioned fields because they received the application after 10/3/2015, correct?

The Getting it Right guide says FIs report NA for "purchased Covered Loans for which Applications were received by the selling entity prior to October 3, 2015." So, am I to assume that if we have a CD for the loan, we report on it?

Thanks in advance!

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#2249781 - 02/25/21 07:46 PM Re: Purchased Covered Loan - Loan Costs wblewis935
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
So, am I to assume that if we have a CD for the loan, we report on it?

Yes.

Page 99 - GIR

1. The amount of total loan costs as disclosed, pursuant to Regulation Z, on Line D
of the Closing Cost Details page of the Closing Disclosure. The Financial Institution
reports the total loan costs if a Closing Disclosure was provided for the Covered Loan.
12 CFR 1003.4(a)(17)(i).

And from 1003.4(a)(17)

2. Purchased loans—applications received prior to the integrated disclosure effective date. For purchased covered loans subject to this reporting requirement for which applications were received by the selling entity prior to the effective date of Regulation Z, 12 CFR 1026.19(f), a financial institution complies with § 1003.4(a)(17)(i) by reporting that the requirement is not applicable to the transaction.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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