We are looking at working with our local Habitat for Humanity organization. We will be completing the documents, closing the loan in our name, fund the loan and the loans will be on our books but we will not be making the credit decision. Habitat will do all the underwrite, qualify the person, and send us the information. Will these loans be HMDA reportable as a purchase loan...I know that it would not be an origination and I feel like it is a stretch as a purchase? We are trying to get credit for HMDA loans on the CRA exam. I'm thinking we can get credit for CRA Service and possible Investments since the loans will be at a 0% rate but I can't get a good feeling for credit on the loan side. Thanks for any help!!

Interesting question. If the loan closes in your name, with your funds and remains on your books and you service the loan, and all Habitat does is tell you whether the applicants are approved. I think you need to visit with legal counsel to determine whether or not Habitat is acting as your agent under State law. Otherwise, I would be calling my EIC because this arrangement does not fit within any of the guidance.