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#134133 - 11/25/03 05:45 PM HMDA Reportable - once or twice?
Some Days You Just Can't Win Offline
Gold Star
Some Days You Just Can't Win
Joined: Feb 2002
Posts: 461
Mississippi River Valley
It's been a long morning already and I guess I'm not thinking straight, but I need help with determining whether or not a loan should be reported once or twice.

scenerio:
Bank A is doing the underwriting for Bank B. Customer decides to withdraw prior to credit decission is made in May. Bank B continues discussions with customer. Bank B makes loan to customer in August making their own credit decission this time.

Do both Bank A and Bank B report both loans?

Does it make any difference that Bank B is a branch of Bank A?

Please help unconfuse me! Thanks!
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CRA
#134134 - 11/25/03 07:55 PM Re: HMDA Reportable - once or twice?
hmdagal Offline
Power Poster
hmdagal
Joined: Dec 2002
Posts: 3,842
Assuming the same application was used for the entire process, I'ld report the final action taken - loan originated.

If Bank B is a branch of Bank A, then there is only one LAR. If they are affiliate banks, and have separate LAR's, it should be reported on Bank B's LAR.

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#134135 - 12/02/03 02:26 PM Re: HMDA Reportable - once or twice?
Anonymous
Unregistered

IMO Bank A reports a withdrawn application. Since Bank A received an application on which it was going to make a credit decision, Bank A has to report it. Bank B would report an origination.

Also, how can you have a bank that is a branch of another bank? Either they are the same bank or they're not.

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