Answer:
Servicing is not a factor for reporting. The financial institution that makes the credit decision reports. From page 6 of the GIR.
Brokered or CorrespondentLoans: Who Reports?When a covered institution makes a loan through a third party such as a broker, the institution, rather than the third party, reports the loan if the institution makes the credit decision. Data on loan applications that do not result in an origination must also be reported by the entity thatmakes the credit decision. Consult staff comments to Regulation C, 1003.1(c)-2 through -7 for more guidance.
First published on BankersOnline.com 3/26/12
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