Is there a requirement that you have an LEI & ULI if you are not HMDA reportable?

An investor might require it if you are selling into the secondary market, but otherwise no.

Thank you. It is an investor and we are not HMDA reportable, so trying to figure out what we needed to do.

You would need apply for an LEI number.

They probably got a flag from your UCD file submission. Are they specifically aware that you are exempt from HMDA reporting?

They are now. This is the first one they have asked for it on and they have purchased them up until now. Not sure what made the change. I'm not real familiar with investors - but learning!

3. ULI—purchased covered loan. If a financial institution has previously assigned a covered loan with a ULI or reported a covered loan with a ULI under this part, a financial institution that purchases that covered loan must report the same ULI that was previously assigned or reported. For example, if a loan origination previously was reported under this part with a ULI, the financial institution that purchases the covered loan would report the purchase of the covered loan using the same ULI. A financial institution that purchases a covered loan must use the ULI that was assigned by the financial institution that originated the covered loan. A financial institution that purchases a covered loan assigns a ULI and records and submits it in its loan/application register pursuant to § 1003.5(a)(1) if the covered loan was not assigned a ULI by the financial institution that originated the loan because, for example, the loan was originated prior to January 1, 2018, or the loan was originated by an institution not required to report under this part.