Answer:
Don’t try to equate fields that are driven by separate requirements. Many investor loans will fall into this reporting category if the institution that received the application does not have delegated credit authority but received the application and documented the loan as payable to them. This will be a very common HMDA reporting situation in investor situations when the correspondent does not have credit authority and therefore does not report the transaction.
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HMDA Review – Answers to Common Revised HMDA Questions
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