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#508367 - 03/06/06 03:56 PM Is This Double Reporting?
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
Here is a question that I received from our Investment Manager:"Can we claim credit for low income mortages booked by our loan department but then sold to FNMA and securitiized into an investment and purchased by the investment department?"

I thought this was covered in a past Q & A, with the answer being "no". But I can't find it. Would this be considered double-counting: reporting the mortgage on a HMDA LAR (since the mortgage activity is considered in the CRA examination) and then as an investment?

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CRA
#508368 - 03/07/06 08:01 PM Re: Is This Double Reporting?
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
Yeah, thanks for all of your responses. (I really am kidding, and smiling.) I found it in the 2001 Q&A.

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#508369 - 03/07/06 11:10 PM Re: Is This Double Reporting?
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
Sorry upstate, but I haven't had time to respond to your question posted yesterday (can you believe, sometimes I do work for clients who actually pay me for my advice?).
Since you already discovered the answer here is the quote from the Q & A as you correctly cited:
§ll.23(b)–2: If home mortgage
loans to low- and moderate-income
borrowers have been considered under
an institution’s lending test, may the
institution that originated or purchased
them also receive consideration under
the investment test if it subsequently
purchases mortgage-backed securities
that are primarily or exclusively backed
by such loans?
A2. No. Because the institution
received lending test consideration for
the loans that underlie the securities,
the institution may not also receive
consideration under the investment test
for its purchase of the securities. Of
course, an institution may receive
investment test consideration for
purchases of mortgage-backed securities
that are backed by loans to low- and
moderate-income individuals as long as
the securities are not backed primarily
or exclusively by loans that the same
institution originated or purchased.
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