Posted By: Skittles
'Initially Payable to Institution' - 09/06/18 01:55 PM
We've had a question come up that we can't definitively answer. If a mortgage loan is not originated; however we know that it would be initially payable to our institution (they all are) should we use a code '1' or a code '3'? From my reading of the regulation and the FIG I believe we should use the code '1'.
Thank you!
Posted By: RR Joker
Re: 'Initially Payable to Institution' - 09/06/18 02:08 PM
Section 1003.4(a)(33)(ii) requires financial institutions to report whether the obligation arising from a covered loan was or, in the case of an application, would have been initially payable to the institution.
Posted By: Island Dreaming
Re: 'Initially Payable to Institution' - 09/06/18 02:10 PM
For what it's worth - we report all with code '1' as all of ours are also initially payable to our institution. We just completed a data integrity review which included 2018 data and our exam team agreed.
Posted By: RR Joker
Re: 'Initially Payable to Institution' - 09/06/18 02:11 PM
That's not true for everyone, though.
Posted By: Skittles
Re: 'Initially Payable to Institution' - 09/06/18 02:14 PM
Thank you for confirming our thoughts, Joker and Island. It's always nice to have backup!!