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In 2018 we originated a construction loan to build apartments and sold a total of 90% of the loan to several institutions. In 2020 we refinanced the construction loan to permanent financing. The participation agreements from 2018 remain in effect. Am I correct to include the 2020 loan as HMDA reportable? Would the HMDA field “Type of Purchaser” be 0-NA since the participation was sold in 2018 and not 2020?
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