Skip to content
BOL Conferences
Thread Options
#2232657 - 03/09/20 05:59 PM Purchasing Loans
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
We are looking to purchase some HMDA reportable loans this year. I would like to hear from those of you that have purchased to learn how you e ensure that all of the data for the LAR is correct. My understanding is that we receive a spreadsheet and that we take the information directly from the spreadsheet. Seems to me that we are responsible for verifying every data element.

Would appreciate learning how this is managed for those that are doing this.
_________________________
TryingToComply
CRCM

Return to Top
HMDA

   
HMDA Academy
#2232658 - 03/09/20 06:04 PM Re: Purchasing Loans TryingtoComply
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 562
Petersburg, VA
We purchased a few mortgages a few years back. We got the entire scanned loan file and pulled our data from that.

Return to Top
#2232663 - 03/09/20 07:04 PM Re: Purchasing Loans TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
Thanks for responding. That seems like the right thing to do.
_________________________
TryingToComply
CRCM

Return to Top
#2232666 - 03/09/20 08:14 PM Re: Purchasing Loans TryingtoComply
hmdagal Offline
Power Poster
hmdagal
Joined: Dec 2002
Posts: 3,841
We buy loans and also have access to the loan files to review HMDA data.

You might want to ask for a sample data spreadsheet to be sure that you will get everything that you need, and that it's in a format that you can use.

Return to Top
#2232670 - 03/09/20 09:00 PM Re: Purchasing Loans TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
Thanks hmdagal. Apparently, that is what we did in the past and there were some errors noted with age. These were applications from 2018 and my impression is that the originator had some system issues. Do you verify the data in the loan files to the spreadsheet to ensure it is correct?
_________________________
TryingToComply
CRCM

Return to Top
#2232678 - 03/09/20 10:37 PM Re: Purchasing Loans TryingtoComply
hmdagal Offline
Power Poster
hmdagal
Joined: Dec 2002
Posts: 3,841
We import the data from the spreadsheet to our HMDA software before verifying it. It's easier for us when it's in the same format as our other loans.

Over the years we've bought from a number of different places and have had issues with data formatting or incorrect information. For example, if a bank sends you the information from their LAR, the action taken date will be incorrect (it will be the date they originated the loan, not the date you bought it) and since these loans are from last year, the loan amount will likely be wrong as well. Data formatting issues could relate to the software you're importing into, and would include things like number of decimal places or date format, or even the type of data that you can import - are the fields text or numeric?

Return to Top
#2232963 - 03/13/20 07:51 PM Re: Purchasing Loans TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
Thanks everyone for your insights!
_________________________
TryingToComply
CRCM

Return to Top
#2234664 - 04/13/20 04:04 PM Re: Purchasing Loans TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
Are we required to report the age on purchased loans or can we enter N/A?

Paragraph 4(a)(10)(ii)
1. Applicant data—completion by financial institution. A financial institution complies with § 1003.4(a)(10)(ii) by reporting the applicant's age, as of the application date under § 1003.4(a)(1)(ii), as the number of whole years derived from the date of birth as shown on the application form. For example, if an applicant provides a date of birth of 01/15/1970 on the application form that the financial institution receives on 01/14/2015, the institution reports 44 as the applicant's age.

2. Applicant data—co-applicant. If there are no co-applicants, the financial institution reports that there is no co-applicant. If there is more than one co-applicant, the financial institution reports the age only for the first co-applicant listed on the application form. A co-applicant may provide an absent co-applicant's age on behalf of the absent co-applicant.

3. Applicant data—purchased loan. A financial institution complies with § 1003.4(a)(10)(ii) by reporting that the requirement is not applicable when reporting a purchased loan for which the institution chooses not to report the age.
_________________________
TryingToComply
CRCM

Return to Top
#2234665 - 04/13/20 04:15 PM Re: Purchasing Loans TryingtoComply
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I think what you highlighted in red is pretty clear?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2234671 - 04/13/20 04:31 PM Re: Purchasing Loans TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
Well, I'm glad you agree. Our EIC does not agree. smile
_________________________
TryingToComply
CRCM

Return to Top
#2234676 - 04/13/20 04:44 PM Re: Purchasing Loans TryingtoComply
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Show them page 58 of the 2020 Getting It Right Guide:

A Financial Institution may, but is not required to, report the age of an applicant for purchased Covered Loans. If a Financial Institution chooses not to report the applicant’s age for a purchased Covered Loan, the Financial Institution reports that the data point is not applicable. 12 CFR 1003.4(b)(2); comment 4(a)(10)(ii)-3.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2234677 - 04/13/20 04:48 PM Re: Purchasing Loans TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
Ah! Just what I need!!
_________________________
TryingToComply
CRCM

Return to Top

Moderator:  SMQ, CRCM