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Commercial Participation Loan Subject to HMDA?

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Question: 
Are commercial loans that are purchased from another bank as a Participation Loan with only a portion of the total loan purchased subject to HMDA reporting by Participating Bank when secured by rental homes, etc?
Answer: 

Participations purchased are not reported, even if the purchasing institution participated in the underwriting. Refer to page D-2 in the HMDA Getting it Right Guide.

First published on BankersOnline.com 4/8/13

First published on 04/08/2013

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