Our bank used to have a robust mortgage program, including secondary market loans where we carried the loans on our books for 30-45 days pending sale. We have since terminated that program and now are only doing mortgages which are ARMs (retaining in the portfolio). We did just enter in to a broker referral agreement with a mortgage broker and are doing RESPA compliant referrals to this broker.

My question: In our CRA List of lending services, is it appropriate to indicate that we offer a whole host of mortgage loans (RD, VA, FHA, 30 year fixed, etc) if all we are doing is facilitating the transaction with a non-affiliated mortgage entity? Is that referral process enough to say that we offer these types of loans or is that misleading? (They are not on our HMDA LAR)

We have GSE loans such as FHA, VA, USDA, OHFA, and HomePath. These loans are not originated by us, they do not hit our books. We take the application, provide disclosures, collect an appraisal fee and pass it on to a broker. Should these loans be listed in our CRA file as Products and Services?

If you are providing a financial service to people in the community (and you appear to be in this case - are you providing any assistance helping with the application?) then you should be alright claiming the service for credit (community services). I would suggest compiling the income data on applicants which hopefully will show that the majority of the people you helped would qualify as LMI borrowers. Government-insured loan processing services also may qualify as flexible and innovative or complex and responsive to community needs.

Yes, we take the application, pull credit, collect income documentation, etc.

Thank you for your response!

While on the subject of CRA Public File.....
(a)(5) A list of services generally offered at the bank's branches - should that list include grandfathered accounts (we are no longer opening new accounts)? If it is not a requirement, is there any reason why we would want to include a list of accounts no longer offered but we are still maintaining?

We only list those accounts we are currently offering, not those grandfathered accounts that we are servicing but no longer offering. Zero concern from regulators on this process. You can include the grandfathered accounts in the public file, but my opinion would be "why bother?" unless it is perhaps easier for you to not have to maintain separate "offering" and "grandfathered" lists.

Thank you for your input!