HMDA and Third Party Broker Applications

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Question:

As a lender, if we receive a third party application and the GFE is incorrect, could we re-issue a new GFE? If we receive an application from a third party broker (application only) and issue a GFE, is this considered a HMDA reportable loan, although we are not making a decision on this yet, and do not know if it will eventually be a viable loan?

Answer:

First part. No. See page 10 of the 4/2/10 FAQs Q&A # 29.

Second part. If the request meets the definition of a home purchase, home improvement or a refinancing you have a loan subject to HMDA reporting regardless if it turns out to be "viable" or not. If it doesn't then you have a denial to report.

First published on BankersOnline.com 1/24/11