Type of Purchaser
Hello, I am working on HMDA information and believe that I have been entering Type of Purchaser incorrectly. Would Investors like: IndyMac Bank, Wells Fargo Bank, CountryWide Bank, CitiMortgage Bank be considered Code 6-Commercial Bank,savings bank or savings association, or Code 7 - Life insurance company, credit union, mortgage bank, or finance company, or Code 5 - Private securitization
According to the FFIEC website, use code 5 if the following applies: "Code '5' is to be used for securitizations by purchasers other than by one of the government-sponsored enterprises identified in codes '1' through '4'. If an institution selling a loan knows or reasonably believes that the loan will be securitized by the institution purchasing the loan, then the seller should use code '5' for "private securitization" regardless of the type or affiliation of the purchasing institution. Reasonable belief or knowledge could, for example, be based on the purchase agreement or other related documents, the institution's previous transactions with the purchaser, or the purchaser's role as a securitizer (such as an investment bank). If an institution selling a loan does not know whether the purchaser will securitize the loan, and, the seller knows that the purchaser frequently holds or disposes of loans by means other than securitization, then the seller should use one of codes '6' through '9', depending on the nature of the purchaser." Code 6 would be used f the following applies: "Use code '6' if the subsidiary is, itself, a depository institution (a commercial bank, savings bank, or savings association). If the subsidiary is not a depository institution, such as a mortgage company or finance company, use code '7'. If the subsidiary is an institution of a type other than the types identified in codes '6' and '7', however, use code '9.' Notwithstanding the foregoing, if the subsidiary is an affiliate of the seller, itself, then use code '8'. " And finally code 7 would be used if the following applies: "A "mortgage bank," often referred to as a mortgage company, means, for these purposes, a non-depository institution that purchases mortgage loans and typically originates such loans. A "mortgage bank" might be an affiliate or a subsidiary of a bank or thrift holding company or it might be an independent mortgage company. In either case, use code '7' - unless the purchaser is an affiliate of the seller, itself, in which case use code '8'. "