Affiliate reporting Per the Guide
"If an institution elects to have an affiliate’s home mortgage lending considered in its CRA evaluation and the affiliate is a HMDA reporter, the institution must be prepared to identify those loans reported by its affiliate under 12 CFR part 1003 (Regulation C, implementing HMDA). At its option, the institution may either provide examiners with the affiliate’s entire HMDA disclosure statement or just those portions covering the loans in its assessment area(s) that it is electing to have considered. If the affiliate is not required by HMDA to report home mortgage loans, the institution must provide sufficient data concerning the affiliate’s home mortgage loans to enable the examiners to apply the performance tests."
Does this mean that a bank can use the lending of an affiliate for CRA purposes, the bank would not have to purchase the loans from the affiliate, and the loans would be only for CRA, and not for Fair Lending?
Thanks
Rocky
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Integrity. With it, nothing else matters. Without it, nothing else matters.