[HMDA Guy 78]

Is there any guidance available on what number to use for Lender ID # on a Standard Flood Hazard Determination form, in the event that an institution is doing two loans simultaneously for a customer – one to be sold to the secondary market (up to the $417,000 current threshold), and a second “Piggy-back” loan to be maintained in-house as a portfolio loan?

I am checking with our SFHD provider to see if it is possible to enter both numbers, but am not yet sure if that is an option.

[rcooper]

The instructions for the SFHDF state:

3. LENDER ID NO: The lender funding the loan should identify itself as follows: FDIC-insured lenders should indicate their FDIC Insurance Certificate Number; Federally-insured credit unions should indicate their charter/insurance number; Farm Credit institutions should indicate their UNINUM number. Other lenders who fund loans sold to or securitized by FNMA or FHLMC should enter FNMA or FHLMC seller/service number.

Also keep in mind if the loan is sold you must notify FEMA: https://www.ecfr.gov/cgi-bin/text-idx?SID=0508ca16a4bebb26037f5ad014cb8521&node=12:5.0.1.2.28.0.3.10&rgn=div8. Check with your flood vendor to see if this is something they do and what you need to do, if anything.

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