Home Mortgage Disclosure Act (HMDA)/Reg C

When we purchase a loan, our origination system assigns it a new loan number. We do not use the Broker's loan number. Will this have to change with the 2018 data collection?

Regulation C does not prevent you from assigning a new loan number for your own purposes when a loan is purchased; however, this would only be for your own internal use or other regulatory requirements regarding reporting, other than your LAR filing. When reporting the loans for HMDA purposes, loans purchased by your institution for the reportable calendar year (remember purchased loans are not reported quarterly, if applicable to your organization staring in 2020) are required to identify the loan on the LAR submission by reporting the Universal Loan Identifier already established/created by the original institution that originated the loan, and not the loan number you may have created for other purposes.

Citation(s):§1003.4(a)(1)(i); Commentary ¶4(a)(1)(i)-3