[Mary Beth Devillier]

If a purchasing bank purchases 100% of a HMDA reportable loan from an originating bank, does the purchasing bank report the loan on their lar? If this is correct, what is the appropriate application date, the date their borrower applied for the loan or the date of the purchasing bank’s participation agreement?

Thank you in advance for your assistance!

[Kimberly Boatwright, CAMS, CRCM]

Yes, you are required to report the loan on the LAR for the year you acquired it. All information for the reporting fields of a purchased transaction can be found in section 4(a) Data Format and Itemization for HMDA rules. In answer to your question you would report the data of the application and not the date of your purchase.

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