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#2270436 - 05/13/22 08:57 PM HMDA - Are Repurchases Reportable
Bruce Gollop Offline
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Joined: Apr 2021
Posts: 21
Our bank had a loan that was funded in May 2020 and was reported on the 2020 LAR. It was repurchased by the Bank in 2021. Would we have to report this transaction on the LAR for 2021?

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#2270437 - 05/13/22 08:59 PM Re: HMDA - Are Repurchases Reportable Bruce Gollop
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,762
Bloomington, IN
It would be reported on the 2021 LAR as a purchased transaction.

See page 27 in the 2022 GIR.

A purchase includes a repurchase of a covered loan, regardless of
whether the financial institution chose to repurchase the covered loan or was required
to repurchase it because of a contractual obligation and regardless of whether the
repurchase occurred within the same calendar year that the covered loan was
originated or in a different calendar year. Comment 4(a)-5.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2270482 - 05/16/22 06:19 PM Re: HMDA - Are Repurchases Reportable Bruce Gollop
MainStreeter Offline
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Joined: Jun 2014
Posts: 50
If we're reporting a repurchase in the same year- originated in Feb. repurchasing in May- if we already had the HMDA origination entered we're just going back and updating the data fields to reflect this as a purchase now (and updating the various data fields accordingly to align with a purchase). Is that accurate?
We would obviously have the data (ie: application date) from the origination, though it wants NA for the purchase... so we're essentially updating our fields to report what the purchase transaction asks for (I understand demographics are optional so we can still report those if desired).

Direction from someone else indicated that we shouldn't report NA if we have the data, that that's only for the 'typical' purchase of a loan when we received limited information. But based on the GIR, a repurchase is still a purchase, I'm not sure why we'd treat this or report it differently based on what's written.

We haven't had a repurchase in several years and I have not been in this position to see on yet so would appreciate any feedback on the data field level.

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#2270495 - 05/16/22 08:23 PM Re: HMDA - Are Repurchases Reportable Bruce Gollop
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,762
Bloomington, IN
If we're reporting a repurchase in the same year- originated in Feb. repurchasing in May- if we already had the HMDA origination entered we're just going back and updating the data fields to reflect this as a purchase now (and updating the various data fields accordingly to align with a purchase). Is that accurate?

No. They are 2 separate reportable transactions.

But based on the GIR, a repurchase is still a purchase, I'm not sure why we'd treat this or report it differently based on what's written.

You will be reporting the repurchase as a purchased loan therefore I would advise following 1003.4, the FIG and the GIR guidelines for reporting information related to a purchased covered loan.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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