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#1762734 - 11/30/12 02:42 PM Broker Loans
tumbleweed Offline
Member
Joined: Apr 2004
Posts: 86
Michigan
We have gone with a company/broker to increase our HMDA numbers in LMI areas. We (the bank) will underwrite and fund these loans. We will report the originated loans on the banks HMDA LAR. Are we responsible for reporting the denials/withdrawn/approved not accepted applications?
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#1762831 - 11/30/12 04:11 PM Re: Broker Loans tumbleweed
Ishmael Offline
100 Club
Joined: Feb 2011
Posts: 232
Pequod
I think this citation and Comment 2 are the ones on-point:

Official Staff Commentary, s. 1003.1-1(c)-Comment 3
3. Illustrations of the broker rule. Assume that, prior to closing, four investors receive the same application from a broker; two deny it, one approves it, and one approves it and acquires the loan. In these circumstances, the first two report denials, the third reports the transaction as approved but not accepted, and the fourth reports an origination (whether the loan closes in the name of the broker or the investor). Alternatively, assume that the broker denies a loan before sending it to an investor; in this situation, the broker reports a denial.

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