[Angie Cowell]

I was told years ago by a compliance resource company that if we had reserved funds with the investor then we reported the purchaser code for the investor accordingly on the LAR at year end even if we if didn’t officially sell the loan to them until the following year. For example, reserved loans with investor and received commitment, loan closes in December, however wire transaction of funds from investor doesn’t take place until January. Purchaser code reported on LAR relates to investor (such as 6) rather than “0” not being sold in calendar year.

I see nothing in the regulation or HMDA Getting it right to really address this. The purchaser code zero states not sold in calendar year.
We have some system challenges and would really like to report loans of this nature with a zero. Do you see that as a problem?

[rcooper]

We recommend you report them as purchaser code “0”.

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