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.
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The opinions expressed are mine and they are not to be taken as legal advice.