HMDA Info on Brokered Loans

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Question:

We are a de novo bank (8 months old) and our service area has been designated an MSA. For 2004 we will be a HMDA reporting bank. We have a Real Estate department that originates loans under broker agreements with loans being closed in the name of the investors. One of the brokers requires loans to be closed in the bank's name. Do we need to collect information on all brokered loans or just the ones closed in our name? We will be collecting HMDA information on all required loans that we carry on our books.

Answer:

Apparently your bank is growing very rapidly. In addition to having an office in a MSA, your bank's assets must exceed $32 million (probably $33 million for 2004) before HMDA applies.

HMDA reporting responsibility is determined by who makes the credit decision, not the name of the party in whose name the loan is closed.

First published on BankersOnline.com 2/2/04