Well, I really wasn't trying to debate but rather point out the need for small filers to talk to their investors.
And I do agree with you, Randy, that the secondary market has always required more - it is a cost of doing business.
Name one piece of HMDA data that a smaller reporter would have to recreate that is not already in a file that is prepared to secondary market standards?
I was referring to reporters that may have to manually create their LAR and manually compile data. Yes, the information is always in the file, but not necessarily on a silver platter (my term) that the secondary market may want.
Why would an exempt small reporter have to fully report there secondary market loans on their own HMDA LAR. A purchaser could care less what the seller has reported.
They wouldn't have to but may choose to in order to have the "silver platter" ready for the investor. Even if they don't report it (which is what I would recommend), creating the silver platter for the investor would be the same amount of work.
The point I was trying to make (which apparently didn't happen) was that small reporters who sell on the secondary market should make sure they have conversations with their investors to ensure they understand their investor expectations.