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If we have determined that we will be exempt from HMDA reporting, do we still need to register for an LEI (Legal Entity Identifier)?
The Legal Entity Identifier is utilized as an identifier for the financial institution on the HMDA LAR as well as built into the Universal Loan Identifier (ULI) that is utilized for each loan or application placed on the LAR. If the financial institution is exempt there is no reason to register for an LEI. If; however, the bank does become a covered financial institution, you will need to register for the LEI. It typically takes 3 business days to receive.
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