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#2256000 - 06/25/21 08:58 PM Loan Sold and Repurchased in the Same Year
Tonya Cannon, CRCM Offline
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Joined: Oct 2015
Posts: 6
If an originated loan is sold to an investor and then repurchased in the same year, how is that reported as two transactions (the origination and the purchase) on my LAR given that the ULI carries through all 3 transactions? What am I missing?

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#2256001 - 06/25/21 09:04 PM Re: Loan Sold and Repurchased in the Same Year Tonya Cannon, CRCM
raitchjay Offline
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Joined: Oct 2009
Posts: 8,515
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I'm not sure i'm following....yes, both entries on your LAR (the origination and the repurchase) will have the same ULI, but that's the nature of the beast. It's the same loan. Is your LOS or software somehow causing you difficulties because the same ULI is on your LAR twice?
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#2256002 - 06/25/21 09:06 PM Re: Loan Sold and Repurchased in the Same Year Tonya Cannon, CRCM
raitchjay Offline
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Paragraph 4(a)(1)(i)
1. ULI—uniqueness. Section 1003.4(a)(1)(i)(B)(2) requires a financial institution that assigns a universal loan identifier (ULI) to each covered loan or application (except as provided in § 1003.4(a)(1)(i)(D) and (E)) to ensure that the character sequence it assigns is unique within the institution and used only for the covered loan or application. A financial institution should assign only one ULI to any particular covered loan or application, and each ULI should correspond to a single application and ensuing loan in the case that the application is approved and a loan is originated. A financial institution may use a ULI that was reported previously to refer only to the same loan or application for which the ULI was used previously or a loan that ensues from an application for which the ULI was used previously. A financial institution may not report an application for a covered loan in 2030 using the same ULI that was reported for a covered loan that was originated in 2020. Similarly, refinancings or applications for refinancing should be assigned a different ULI than the loan that is being refinanced. A financial institution with multiple branches must ensure that its branches do not use the same ULI to refer to multiple covered loans or applications.
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#2256006 - 06/25/21 09:33 PM Re: Loan Sold and Repurchased in the Same Year Tonya Cannon, CRCM
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,344
Bloomington, IN
I'm not sure I understand the concern either. The original loan will be reported with Action Taken Code 1 and the repurchased loan will be reported with an Action Taken Code 6.

3. ULI—purchased covered loan. If a financial institution has previously assigned a covered loan with a ULI or reported a covered loan with a ULI under this part, a financial institution that purchases that covered loan must report the same ULI that was previously assigned or reported. For example, if a loan origination previously was reported under this part with a ULI, the financial institution that purchases the covered loan would report the purchase of the covered loan using the same ULI. A financial institution that purchases a covered loan must use the ULI that was assigned by the financial institution that originated the covered loan. A financial institution that purchases a covered loan assigns a ULI and records and submits it in its loan/application register pursuant to § 1003.5(a)(1) if the covered loan was not assigned a ULI by the financial institution that originated the loan because, for example, the loan was originated prior to January 1, 2018, or the loan was originated by an institution not required to report under this part.
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#2256141 - 06/29/21 09:35 PM Re: Loan Sold and Repurchased in the Same Year Tonya Cannon, CRCM
Tonya Cannon, CRCM Offline
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Joined: Oct 2015
Posts: 6
Thank you! Yes, I was concerned about having the duplicate ULI on the LAR. Upon further research I see that the edit specifications allow for the same ULI to be reported with different action codes.

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