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Confusion with brokered loans..

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  • #6318
    kcco
    Member

    Some confusion has come up involving loans were we are the broker. I understand that whoever makes the credit decision reports HMDA. The confusion comes in the following scenario: We take an application, send it through the company’s underwriting “system” aka: GUS. If for some reason “GUS” spits out “ineligible” or “refer” (they don’t want the loan) then the process stops and I am told at that point an Underwriter never sees it. To me, that is their underwriter. Their company made some kind of decision, either from a “system” or from an individual (underwriter). If we have the findings from GUS, then I am inclined to NOT report this loan on our LAR since we made no credit decision. Furthermore, we should not be preparing Adverse Actions on the transcations. Is this correct?

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