Digital Risk Staff Attorney Meaghan James in Housing Wire about HMDA Loan Reporting by Non-delegated CorrespondentsDecember 22, 2017
Digital Risk's experts are featured in Housing Wire’s latest series of answering some significant HMDA questions.
The latest article titled "Your top 10 HMDA questions answered: Part 7" features Digital Risk Staff Attorney Meaghan James talking about who really needs to report HMDA data, and who are exempt.
"Under HMDA, applications and originations are only reported by one financial institution," Digital Risk Staff Attorney Meaghan James said. "The key factor in determining who reports the transaction is who made the credit decision on the loan."
"Therefore, in the situation of non-delegated correspondents where the investor underwrites the loans, it is the investor making the credit decision, and therefore the investor will report the loan, and the correspondent does not," James said. "This is assuming that, under applicable state law, the investor is not considered to be acting as an agent for the correspondent."
Read the full informative piece here.