Investor HMDA Data

Posted By: referwithcaution

Investor HMDA Data - 04/26/22 07:21 PM

I have a question about the reportability of a particular application. Our institution has an Investor that does their own Underwriting and Approval process. For originations, I know that I do not report these applications as we did not make a credit decision. However, for instances where an application was withdrawn before a credit decision was made or one that is approved but not accepted, should I still exclude them?
Posted By: Dan Persfull

Re: Investor HMDA Data - 04/26/22 07:29 PM

The investor would report those on their LAR.
Posted By: Dan Persfull

Re: Investor HMDA Data - 04/26/22 08:09 PM

Let me rethink this.

Approved but not accepted the investor would report.

Withdrawal - since a withdrawal can only be made prior to a loan decision I think these would fall on you to report since no decision was rendered by the investor.