I began this on an old thread, so I wanted to move it to a new one.

We originated and sold a loan in 2021. In 2022, we need to repurchase it. Repurchases are supposed to be reported as purchases on your HMDA submission.

There are specific fields that need to be "N/A" for purchased loans, such as application date. Since we originated this loan, the loan file has an application date. Question: Should we update the necessary fields on the original loan file to report it as a purchased loan? It seems weird to me to change these certain fields in a loan file since we originated it.

Yes- you did already ask this and I think I said that I have no idea what you mean by update the "loan file". You had a loan origination LAR entry on your 2021 and you will have a totally separate purchased loan LAR entry on your 2022 LAR. Whether you were the originating lender does not impact the fields that you have to report on a purchased covered loan.

1003.4(a)(1)(ii) Except for purchased covered loans, the date the application was received or the date shown on the application form.

Thank you sir! I think my lack of experience in HMDA reporting is making my question not make sense. I really appreciate this education.

I thought that when you are pulling data for your HMDA LAR submission, that LAR entry simply includes data fields pulled from the loans in your Loan Origination System. So for instance, the third data point is the Application date. When I pull my HMDA data from our LOS to send to the CFPB, I thought it was just pulling in the “application date” field, which wound already have a date in it, since we originated the loan. Does that make sense? Am I of thinking this completely wrong?

I really cannot speak to how your LOS system works or interfaces with your HMDA reporting. But if you are purchasing a loan, even if you owned it some time ago, I am not sure the best thing to do would be to combine the two records.

We manually enter repurchases into our HMDA reporting software.

Thank you both for your input! This conversation has been extremely helpful.

There's a good chance that what you think happens (about the download from your LOS is accurate), but, there should be a point somewhere in the process where you can edit/correct the data as needed to ensure validity.