We're using an auto-underwriting system for our mortgage division and the AUS is "programmed" to Fannie Mae/Freddie Mac & investor guidelines. If we receive a decline from the AUS, but the investor never reviews the application, it would be HMDA reportable for us. Correct? OR because the investor has programming parameters built into the AUS does reporting fall to them? Which holds true?

See Pg D-2 of GIR. Especially #4. Broker's use of investor's underwriting criteria.

You are responsible for HMDA reporting.

Thanks, hmdagal. That's EXACTLY what I was looking for.