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Just getting back into HMDA after some time off, so would like some guidance.
Our institution sometimes pulls DU and LP at the beginning of the application process. I am trying to determine if I need to report both. When looking at the 1008, only 1 of the AUS’s is listed, so should that be the only one I report?? For example, DU and LP both pulled day after application, but the LP was pulled 3 other times throughout the process of the loan, and the DU was only pulled at application, and the LP is the one that is listed on the 1008. Could we not say that the LP was the one relied upon to evaluate the application?
When you obtain multiple results the name of the AUS used by the financial institution to evaluate the application and the result generated by that AUS as determined by the following principles.
i. If a financial institution obtains two or more AUS results and the AUS generating one of those results corresponds to the loan type reported pursuant to § 1003.4(a)(2), the financial institution complies with § 1003.4(a)(35) by reporting that AUS name and result.ii. If a financial institution obtains two or more AUS results and the AUS generating one of those results corresponds to the purchaser, insurer, or guarantor, if any, the financial institution complies with § 1003.4(a)(35) by reporting that AUS name and result.
iii. If a financial institution obtains two or more AUS results and none of the systems generating those results correspond to the purchaser, insurer, or guarantor, if any, or the financial institution is following this principle because more than one AUS result is generated by a system that corresponds to either the loan type or the purchaser, insurer, or guarantor, the financial institution complies with § 1003.4(a)(35) by reporting the AUS result generated closest in time to the credit decision and the name of the AUS that generated that result.
iv. If a financial institution obtains two or more AUS results at the same time and the principles in comment 4(a)(35)-3.i through .iii do not apply, the financial institution complies with § 1003.4(a)(35) by reporting the name of all of the AUSs used by the financial institution to evaluate the application and the results generated by each of those systems.
The Commentary for § 1003.4(a)(35) provides examples for each of the principles.
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