[Angie Cowell]

HMDA- Purchasing a loan

We made a loan several years ago and sold to an investor. We are now purchasing this loan back. When it comes to the monitoring information, the HMDA Getting It Right manual states to use the not applicable codes when loan is purchased if it is unavailable. None of my documentation for the re-purchase has the monitoring information, however I still have the information in my system from when we made the loan years before. Do I report this information since I still have information in my system from the past, or is the fact that I do not have this information in my documents pertaining to the re-purchase mean it is unavailable?

I also have the same question in regards to income.

I am trying to determine what the expectation is of how far I go to determine and report this information.

Thank you.

[kowsley]

Institutions may, but are not required to, report applicant ethnicity, race, or sex of the applicant or co-applicants for purchased loans. Income is also not required to be reported on purchased loans. Even if this is a loan you originated in the past, it is now considered a purchased loan so you may report NA in those fields. Treat the loan as a purchase, not an origination and follow the rules in Appendix A closely for a purchase.

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