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HMDA-LAR Code - Type of Purchaser |
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Hi, I work for a start-up mortgage banker and we are trying to determine what code to use for our investors. Does anyone know what the industry typcially uses for an investor who is not a state or federally chartered institution nor a credit union? They could be an affiliate or a wholly owned subsidiary of one, but they are truly a separate entity. Is it 7 or 9? If the answer is 7, then what type of investor would be coded a 9? I look forward to your responses! Tracy 9 is what we report quote: Code 7 would be the appropriate code for a mortgage company, finance company, or credit union. An example of an entity that would be code 9 is a Real Estate Investment Trust (REIT) that does a whole loan purchase. Another example is an individual that purchases certain whole loans for financial reasons other than an arms length transaction. I agree the purchaser code of 9 being used for a REIT providing that the REIT is not held by an affiliate of the mortgage company at which point the purchaser code would be 8 (Affiliate Purchase). Though you would never use a purchaser code of 5 since it is normally a whole loan sale not a securitization. quote: Awesome example of TCF usage!!! You guys are awesome. I really appreciated everyone's feedback last year on this question I posted! Here is an interesting one... We signed up with an investor who is a coporation. Our approval letter is from this corporation and they provide the Seller's Guide and program information; however, the Loan Purchase Agreement is between us and a Bank. The purchase agreement mentions the corporation we are approved with. The purchase advices come from the bank. The corporation we are approved with services the loans sold to the bank under their approval. These two entities are affiliated with each other, but not to us. For HMDA purposes, I plan to code this as a "6" because it is the bank who actually purchases the loan, not the corporation we have the approval with. Would anyone disagree? |
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