FRB FAQs-Our bank brokers most of its mortgage loans through another bank. Do I report on our LAR only those loan applications that do not close with the other bank?

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Q:  Our bank brokers most of its mortgage loans through another bank. Currently, I report applications denied by our bank or withdrawn while still at our bank. Do I report on our loan application register (LAR) only those loan applications that do not close with the other bank?
 
A:  The entity that makes the credit decision on a loan application has responsibility for reporting that application if the loan is HMDA-reportable. As noted in comment 203.1(c)-2 of the Official Staff Commentary (Commentary) for Regulation C , an institution that makes a credit decision prior to closing reports that decision regardless of whose name the loan closes in. Therefore, your institution would report any applications for which it makes the credit decision, whether or not those applications close with the other bank.

 

This can be found in - HMDA FAQ#2 of the FAQs.  The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/

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