Question: Where can we find guidance on what needs to be reported on the HMDA LAR for purchased loans? Our institution is purchasing loans from another institution. We will not retain the servicing when the loans are purchased.
Are these reported as purchase transactions on the LAR?
Do we report all fields (loan amount, income, action taken date, rate spread, etc.)?
Answer: The place to look is in Appendix A of Regulation C, the Instructions for Completion of Loan/Application Register, found at https://www.ecfr.gov/cgi-bin/text-idx?SID=27d7be90353c8844d5d4e72135801dd9&mc=true&node=pt12.8.1003&rgn=div5#ap12.8.1003_16.a. The short answer on what information you will enter on your LAR for purchased loans is that this information will generally be the same as what you enter for loans you originate – with a few twists. For example, you do not have to (but may) collect and report the ethnicity, race/national origin, and sex for applicants on purchased loans. You need to look through Appendix A for other instances of changed requirements.
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