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#2203233 - 01/16/19 11:51 PM Definition of origination for HMDA
angela aniol Offline
Junior Member
Joined: Nov 2017
Posts: 48
I am reviewing the Lines of Credit Thresholds. It says if we originate 500 Open End Lines of Credit for the past 2 years which leads me to a question. Origination - does that mean applications taken or loans booked?

Thank you.

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#2203254 - 01/17/19 01:45 PM Re: Definition of origination for HMDA angela aniol
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
It includes only originations and does not include denials, withdrawn, or approved but not accepted. The real challenge is counting which loans would count during 2017 (and 2016 if applicable) as the old rules and new rules don't fully align. Basically, for those years you have to report based on the number or originations that would have been reportable under the current/new rules.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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