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#2269665 - 04/26/22 07:21 PM Investor HMDA Data
referwithcaution Offline
Junior Member
Joined: Feb 2022
Posts: 25
I have a question about the reportability of a particular application. Our institution has an Investor that does their own Underwriting and Approval process. For originations, I know that I do not report these applications as we did not make a credit decision. However, for instances where an application was withdrawn before a credit decision was made or one that is approved but not accepted, should I still exclude them?

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#2269669 - 04/26/22 07:29 PM Re: Investor HMDA Data referwithcaution
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,835
Bloomington, IN
The investor would report those on their LAR.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2269674 - 04/26/22 08:09 PM Re: Investor HMDA Data referwithcaution
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,835
Bloomington, IN
Let me rethink this.

Approved but not accepted the investor would report.

Withdrawal - since a withdrawal can only be made prior to a loan decision I think these would fall on you to report since no decision was rendered by the investor.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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