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#2267882 - 03/18/22 04:06 PM Purchased loans
Auditor16 Offline
Junior Member
Joined: Jan 2018
Posts: 32
Is there an expectation for a FI to perform a QC over purchased (covered) loans and the HMDA data used to file? Or can reliance be provided on the file provided by the seller and no QC is expected? Accuracy of the data is important with the filing, however, I was not certain on the purchased loans piece.

Thank you!

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#2268116 - 03/23/22 04:25 PM Re: Purchased loans Auditor16
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,349
I'm confused. Are you purchasing closed loans that you did not underwrite? If so, the originating bank is responsible for the initial HMDA data reported.

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#2269715 - 04/27/22 06:16 PM Re: Purchased loans Auditor16
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,616
I think the poster is asking about when you purchase the loan and have to include the file on the LAR in the year of purchase. For certain Data Fields, you will have N/A in that case, but in fields where you do need to submit info, yeah, I would monitor such loans for accuracy of information.

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#2269720 - 04/27/22 06:49 PM Re: Purchased loans Auditor16
Inherent_Risk Offline
Gold Star
Joined: Jan 2017
Posts: 374
If it's on your LAR, you're going to be responsible for the data.

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#2269778 - 04/28/22 03:58 PM Re: Purchased loans Inherent_Risk
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,616
Originally Posted by Inherent_Risk
If it's on your LAR, you're going to be responsible for the data.

That's the gist of it smile

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#2269951 - 05/02/22 09:00 PM Re: Purchased loans Compliance NABW
Auditor16 Offline
Junior Member
Joined: Jan 2018
Posts: 32
Yes! Thanks, this is exactly what I was asking.

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