Lender or Originator: Who provides the LAR?

Answered by:

Question:

We are providing the financing on mobile homes and the originator serves the loan. Who is required to record the transaction on the HMDA LAR? are providing the financing on mobile homes and the originator serves the loan. Who is required to record the transaction on the HMDA LAR?

Answer:

Refer to the Commentary to Section 203.1(c) #5. An institution that takes and processes a loan application and arranges for another institution to acquire the loan at or after closing is acting as a "broker." A broker may or may not make a credit decision on an application (and thus it may or may not have reporting responsibilities). If the broker makes a credit decision, it reports that decision; if it does not make a credit decision, it does not report.

So, who makes the credit decision?

First published on BankersOnline.com 8/11/03