Who should report based on the following scenario

I am looking for opinions on the following situation: Our Mortgage Company has entered into business relationships with some smaller banks who need our technology to originate Mortgage loans. These Banks contract with either MI underwriters (Conventional loans) or Bell Mortgage Company Underwriters (FHA Loans) for the underwriting piece of the transactions. These loans are closed in the Banks name and after closing are delivered to our Mortgage Company for purchase. The question is this: Who reports the loans that do not close? are rejected? are withdrawn? According to the response I received from the HMDA help desk, it is the entity that makes the credit decision who should report. The part they would not comment on was the fact that the underwriters are contracting with the Bank to make the decision on their behalf. I checked with MGIC and they do not report, it is their position that they are making the decision on behalf of the Bank, therefore making the Bank the responsiblie reporter. Would that same logic apply to Bell underwriters that are under contract to underwrite for the Banks? Comments or opinions would be most appreciated. Thanks Marci Anderson Bell Mortgage Company