Hi - we are transitioning to using a third party provider for a lot of things and I'm having a lot of questions that come out of that transition. Our third party provider uses a combination of letters and numbers. Our core does not allow for using numbers.

I am aware that for loans being sold; the new servicer frequently changes the number. I am not concerned about those; as we won't be booking them and in our system, they will always be that alphanumeric number which is what I'll report for HMDA. For the ones that we keep in house though - which will probably be a large portion of them - is it acceptable to have a slight change in loan identifier and drop those letters from the loan number? We would still be easily able to identify the file; just knowing that those two letters need added back on; so I believe this satisfies Reg Z's requirement that the loan identification number must be sufficient to enable identification of the transaction. But for the portfolio loans, would I report the loan identifier WITH those letters which is what the underwriting software and all loan does will show; or WITHOUT the letters which is what our core and billing will show? Or did I miss something when thinking about Reg Z that makes making a minor change to the identifier after closing more problematic than I'm thinking?

Our core does not allow for using LETTERS. Letters; not numbers.

If you are talking about the Loan ID on the TRID documents, that may but does not have to have any relationship to a loan number assigned to the loan for processing, so I am a little lost as to your concern.

Short version is, I am wondering which number to report for HMDA. The one WITH the letters or WITHOUT the letters. The numerical portion is going to be the same; but the one system won't accommodate the loan number without the letter; and the other one won't accommodate the loan number WITH the letters. It's not a processing number - that's a whole different number. But the loan number on the LE, CD, note, etc. will not be the same as what it's booked as for servicing (on account of those letters).

Strictly a business decision. The number for HMDA reporting just has to be unique. It does not have to have any relationship to a loan number that is used for processing/servicing.