Purchased loans

Posted By: Auditor16

Purchased loans - 03/18/22 04:06 PM

Is there an expectation for a FI to perform a QC over purchased (covered) loans and the HMDA data used to file? Or can reliance be provided on the file provided by the seller and no QC is expected? Accuracy of the data is important with the filing, however, I was not certain on the purchased loans piece.

Thank you!
Posted By: Truffle Royale

Re: Purchased loans - 03/23/22 04:25 PM

I'm confused. Are you purchasing closed loans that you did not underwrite? If so, the originating bank is responsible for the initial HMDA data reported.
Posted By: Compliance NABW

Re: Purchased loans - 04/27/22 06:16 PM

I think the poster is asking about when you purchase the loan and have to include the file on the LAR in the year of purchase. For certain Data Fields, you will have N/A in that case, but in fields where you do need to submit info, yeah, I would monitor such loans for accuracy of information.
Posted By: Inherent_Risk

Re: Purchased loans - 04/27/22 06:49 PM

If it's on your LAR, you're going to be responsible for the data.
Posted By: Compliance NABW

Re: Purchased loans - 04/28/22 03:58 PM

Originally Posted by Inherent_Risk
If it's on your LAR, you're going to be responsible for the data.

That's the gist of it smile
Posted By: Auditor16

Re: Purchased loans - 05/02/22 09:00 PM

Yes! Thanks, this is exactly what I was asking.