[Anonymous]

We have a loan that was originated in 2010 and was reported appropriately. We participated 60% of the loan to another bank in 2011. Do we need to report anything for 2011?

[JGo9]

In glancing at the HMDA guide to getting it right and by looking at the information that is reported on the LAR, I would say that you would not report the loan again.

To my knowledge there is no way to indicate on the LAR that the loan or a portion of the loan is sold.

On page 9 of the Guide to Getting it Right it states under the heading Transactions Not to be Reported:

The acquisition of only a partial interest in a home purchase or home improvement loan or a refinancing by your institution, even if you have participated in the underwriting and origination of the loan (such as in certain consortium loans).

I know you were the seller and not the buyer to it seems closely related and the closest think I found to your situation.

[jholzknecht]

You indicate the type of entity to which a loan is sold only when the loan is originated in a given year and then is sold to another entity in the same year; otherwise enter code 0.

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