Reporting a loan originated in 2010 but sold in 2011

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    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?


    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.


    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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