Reporting as purchased?

We have a new TPO relationship. We will close the loan in their name then purchase the loan from them. We would report the loan as Loan purchase. It's that simple or am I missing anything?

Who is making the credit decision

We underwrite the loan and close it in their name.

Only one financial institution reports each originated covered loan as an origination. If more than one institution was involved in the origination of a covered loan, the financial institution that made the credit decision approving the application before closing or account opening reports the loan as an origination. It is not relevant whether the loan closed or, in the case of an application, would have closed in the institution's name. If more than one institution approved an application prior to closing or account opening and one of those institutions purchased the loan after closing, the institution that purchased the loan after closing reports the loan as an origination. If a financial institution reports a transaction as an origination, it reports all of the information required for originations, even if the covered loan was not initially payable to the financial institution that is reporting the covered loan as an origination.

Ok, so we would report the loan as originated not purchased. I got hung up on the name in which it was closing not who made the credit decision.