During the past quarter we added FHA as a product but instead of us closing and funding with our money, the loan is approved, closed and funded by our FHA sponsor. This is our first experience brokering loans.

From a HMDA perspective, are the following statements true?
1) If we deny an application before sending it to our FHA sponsor for their underwrite, we then are responsible for HMDA reporting.
2) If the loan is approved by the sponsor and closes in their name, the FHA sponsor reports the loan on their HMDA LAR. we would not report the loan.
3) If the borrower cancels the request before underwriting, the loan is reported on our HMDA LAR.

Thanks for your assistance.

The entity that makes the credit decision reports.

1. True

2. True

3. Depends. If already submitted to the sponsor they report as a withdrawal. If it has not yet been submitted to the sponsor then you would report as a withdrawal.

Thank you Dan for your feedback.