Thread Options
#2253479 - 05/05/21 01:26 PM HMDA Correspondent Action Reporting
Jay Offline
New Poster
Joined: Oct 2017
Posts: 10
We, as the Investor, sometimes underwrite the mortgage with our U/W staff. So this would be a loan from Correspondent "ABC". When we get the loan to UW from ABC, we may sometimes suspend the loan for something (additional information, documentation, etc. - likely to be denied because we don't have what we need) during the Underwrite but BEFORE we make the credit decision. If we didn't make a credit decision and ABC pulls back their loan, how do we document that for HMDA?

I think it looks like a Withdraw, but we would not have the information if the Borrower is withdrawing or just the Correspondent Lender is withdrawing it from us and selling it to a new investor.

Return to Top
HMDA

   
HMDA Academy
#2253609 - 05/06/21 08:00 PM Re: HMDA Correspondent Action Reporting Jay
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,476
Do you send out an NOI requesting the necessary items?

Return to Top
#2253638 - 05/07/21 01:41 PM Re: HMDA Correspondent Action Reporting Jay
Jay Offline
New Poster
Joined: Oct 2017
Posts: 10
No we do not send out a NOI because it is Bank A who is withdrawing the loan from Bank B not the borrower.

Return to Top
#2253639 - 05/07/21 02:00 PM Re: HMDA Correspondent Action Reporting Jay
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 76,979
Galveston, TX
If the correspondent withdraws the application prior to you making a credit decision, then the correspondent would be responsible for reporting. This should all be outlined in your correspondent agreements.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2253652 - 05/07/21 04:05 PM Re: HMDA Correspondent Action Reporting Jay
Jay Offline
New Poster
Joined: Oct 2017
Posts: 10
rlcarey is this listed in any section of the regulation?

Return to Top
#2253666 - 05/07/21 08:05 PM Re: HMDA Correspondent Action Reporting Jay
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 76,979
Galveston, TX
Not really, but the creditor that makes the loan decision reports the loan. If you did not make a decision, then it would fall back to your correspondent. You have no idea who withdrew the application so you cannot report it as withdrawn by the applicant.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2253714 - 05/10/21 04:39 PM Re: HMDA Correspondent Action Reporting Jay
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,476
Well, I was more saying how do they know that additional information is required for you to decision the app. But, I guess however you do the correspondent process. I agree with RL here conceptually. My understanding is if the broker/correspondent takes away the file before you make any kind of decision, or you reject the file (because you are aware of Compliance violations for instance), then you really have no application to speak of.

Return to Top