Home Mortgage Disclosure Act (HMDA)/Reg C

Is a purchased loan by definition a "covered loan" that had an application date prior to 10/03/2015?

A purchased loan is generally a closed-end mortgage loan or an open-end line of credit that is acquired from another entity where the entity purchasing the loan was not the entity making the original credit decision at the time the loan was originated. The date of October 3, 2015 (the effective date of integrated mortgage disclosures under the Truth in Lending Act) is used for excluding the reporting of specific data fields (to be indicated as not applicable) when a loan is purchased and the loan application was taken prior to this date.

In other words, if the loan application was taken prior to October 3, 2015 and the loan is reported as purchased, the following data fields are indicated as not applicable: Total Loan Costs; Borrower-Paid Costs; Discount Points; and Lender Credits.

Citation(s):Commentary ¶4(g)-1ii; Commentary ¶4(g)-2 thru -5; Commentary ¶4(a)(17)(i)-2; Commentary ¶4(a)(18)-2; Commentary ¶4(a)(19)-2; Commentary ¶4(a)(20)-2