How is everyone handling simultaneous loans for the same property with duplicate ULIs?

I have 2 records on my LAR for the same property address where a 1st and a 2nd were taken. They have two different loan numbers, but have the same ULI. Is this acceptable, or should I try to generate a new ULI for one of them?

The loan number is a component of the ULI, so I don't see how you could have different loan numbers and the same ULI. Regardless, you can't report multiple entries with the same ULI, so one needs to be changed.

The loan number does not have to be a component of the ULI. But the statement is correct, two HMDA records cannot have the same ULI - ever - not just in one reporting year.

I guess it doesn't have to be the loan number, but a unique identifier for each loan must be used as part of the ULI.

2. Follows the Legal Entity Identifier with up to 23 additional characters to identify the covered loan or application, which:
 May be letters, numerals, or a combination of letters and numerals;
 Must be unique within the financial institution; and
 Must not include any information that could be used to directly identify the applicant or borrower.

Sounds like the method you use to create the unique loan number portion of the ULI is being based on the customer or some number associated with the customer, and perhaps the date. Is there a way to jazz up the routine for creating that part of the ULI to avoid duplication going forward?

Although not required, having the loan number as a component of the ULI is nice because it avoids the duplication problem. I agree with others that the ULI can never be duplicated. This is a syntactical error and you cannot even submit your HMDA file until you correct all syntactical (and Validity) errors. You *could* just apply a letter to each loan on the property LEI + Your institutions unique code for the loan + letter (A,B,C) + Check Digit.

Great, thank you both.