HMDA Conundrum

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Question:

We handle FHA/VA loans where we do not make the credit decision. The Reg says we report HMDA if we make the decision, but HUD is telling us to report these in addition to the entity making the decision. Should we be reporting them in addition to the lender making the decision?

Answer:

This is a discussion you should be having with HUD to find out why they feel you should be reporting. The Reg. is very clear that the entity that makes the credit decision is the entity that reports the transaction.

First published on BankersOnline.com 7/24/06