I understand that if the originator from whom we purchased the loan provides the ULI, we report that ULI on our LAR.
My question is the LEI - should that be our LEI on all files (originated/internally decisioned and purchased), or do we report the LEI from the ULI, so some purchased loans will have our LEI and others will have different LEI?

First year we are doing bulk purchases from others.

The ULI never changes once it is assigned to the loan.

Follow-up question - We originated, sold and then repurchased some loans in the same year. We are showing duplicate ULI numbers resulting in a macro edit. If we are not changing the ULI (or the account number used in the ULI) how do we resolve the macro edit so that we can submit?

I thought all you had to do was acknowledge a macro edit? They are not a hard fail.

Macro Quality: Edits that check whether the submitted loan/application register as a whole conforms to expected values. A macro quality edit occurs, for example, if the reported percentage of multifamily loans exceeds 10% of the loan/application register entries. The loan/application register cannot be submitted until the filer either confirms the accuracy of all the values flagged by the macro quality edits in the HMDA Platform or corrects the flagged values and re-loads the updated loan/application register to the HMDA Platform.


You clearly have to report the repurchase:

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.