I'm looking for some ideas on how the normal correspondent mortgage registration and rate lock process works. Process in question: correspondent who is authorized to approve on their own - we do not underwrite prepurchase - receives pricing sheets daily which detail how to price the loan (ltv, score, occupancy, prop type, various other factors go into how the rate is set and what price will be paid for the loan). When they register and set a rate, they submit a form that includes the above factors that is used by the corres. area to check that the price is indeed correct and that the loan is eligible for purchase. The $ amount is then hedged until closing. An actual file review takes place after the loan is closed and it is actually submitted for purchase.

Any problem with treating the first step - registration/lock - as just that but not a pre-closing review that would trigger hmda, reg B etc.