I've confused myself yet again. My bank works with several mortgage brokers and correspondent lenders. In all cases, we make the credit decision and report the loan.

What I'm unclear about is whether to classify these loans as "originated" or "purchased." Some brokers/correspondents are table-funded, others use a warehouse line, others use both methods. Notes are in the broker/correspondent name. Is there a simple rule of thumb to tell me whether these are originated or purchased? Seasonally-appropriate thanks for any direction you can offer.

Simple rule of thumb: If you underwrote them, report them as originated.

"In the case of brokered loan applications or applications forwarded through a correspondent, the institution reports as originations the loans that it approved and subsequently acquired per a pre-closing arrangement (whether or not they closed in the institution's name)."

Your brokers or correspondents should not also be reporting the loans: "Loan originations are to be reported only once. If the institution is the loan broker or correspondent, it does not report as originations the loans that it forwarded to another lender for approval prior to closing, and that were approved and subsequently acquired by that lender (whether or not they closed in the institution's name).

Thanks very much. Updating the LAR will keep me busy on Black Friday.

I have a further question on this topic. It is in regards to proper year end cutoff. Below is an excerpt for the Reg C Supplement. We purchase loans from correspondent banks. We do all of the underwriting, do not allow delegated underwriting, report as the originator and report the "Action Taken Date" as the date we acquire the loan (the day we disburse to the correspondent). This date can be up to 10 days or longer (if there are pending items)after the contract date. Does the last sentence below indicate that I have to change the way I report for loans that are not complete by 12/31/2011?

For an example: Contract date 12/30/2011, I do not purchase until
January 6, 2012. Should it be on the 2011 LAR or the 2012 Lar?

Paragraph 4(a)(8) Type of action taken and date.
6. Action taken date—originations. For loan originations, an institution generally reports the settlement or closing date. For loan originations that an institution acquires through a broker, the institution reports either the settlement or closing date, or the date the institution acquired the loan from the broker. If the disbursement of funds takes place on a date later than the settlement or closing date, the institution may use the date of disbursement. For a construction/permanent loan, the institution reports either the settlement or closing date, or the date the loan converts to the permanent financing. Although an institution need not choose the same approach for its entire HMDA submission, it should be generally consistent (such as by routinely using one approach within a particular division of the institution or for a category of loans). Notwithstanding this flexibility regarding the use of the closing date in connection with reporting the date action was taken, the year in which an origination goes to closing is the year in which the institution must report the origination.

It would appear so.
First you're given flexibility to chose closing date vs your disbursement date.
Then the Reg does an about face and says you MUST report the loan in the year it was originated. That means you'll have some that use the disbursement date and some that use the closing date.
I'm in exactly the same position as you with regard to underwriting and purchasing. We use the actual date of the note as the origination date for all loans. Problem solved.