HMDA Reporting/Correspondent-Broker

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    We are entering into an agreement with a mortgage company to act as a correspondent. We will take applications – complete underwriting {mortgage company’s underwriting standards}. The mortgage company will complete a review prior to closing. We will close and fund the loan, the mortgage company will then purchase.

    I think the mortgage company will report loan on their HMDA LAR as originator. However, the are telling me they will report the loan as (6) purchased. They say they are underwriting to determine IF they will purchase the loan and that it is the correspondent who is extending the credit/funds, therefore the correspondent(our bank) would report these as originated loans.

    I appreciate your thoughts and comments.


    Check the HMDA Guide, it talks about “Brokered Loans”. There’s a few clauses that depend on who underwrites the loan.

    Another thing to consider is, are you going to close these loans before finding out if the other bank will purchase? Or are you underwriting w/ their standards in hopes that they’ll purchase? This will make a lot of difference with your HMDA reporting.

    Hope this helps!

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