Case Study: The Effect of Branch Banking
For 12 years, small community bank originated mortgage loans through subsidiary mortgage company which recently had a rush of MLO job apps submitted from MLOs who did not want to go through licensing process. The mortgage company acted quickly when it had an opportunity to add 4 originators and a satellite branch in a strip mall west of the city.
The mortgage company had always done business on that side
of town with a loan originator working from its central location on the other
side of town. The bank was also excited because it had not had a presence on
that side of town and agreed to work with the mortgage company and put a
banking operation inside the mortgage office.
Historically, this area was not in the Metropolitan
Statistical Area (MSA) served by the bank, but the move certainly gave the
mortgage company the additional appearance of financial strength and stability.
More importantly, the bank also had been unsuccessful in writing home improvement
loans in this area of town. Now with a much stronger presence and a branch
bank, that should all change.
Will this change the HMDA reporting requirements of the
Bank?
This would still be considered a branch of the bank/lending organization. It would change their reporting requirements if they manage to sell loans and/or receive loan applications in this area.
ReplyDeleteAdding the home improvement loans will now require the bank to record and report all home improvement activity in its HDMA data moving forward.
ReplyDeleteDarryl Lewis
Yes it will since they will be receiving & processing loans through this branch.
ReplyDeleteThis must be reported for any loans or applications where the company has an office or branch
ReplyDeleteBecause the office will be doing loan servicing in this area it will have to report moving forward.
ReplyDeleteYes, because this particular bank now has successful home improvement loans it will be required to report them.
ReplyDelete1 of 1
ReplyDeleteYes because of the servicing of the loan it will need to be reported annually of the data collected
it will require that the bank record and report
ReplyDeleteall home improvement loans, purchases and refinance activities in its HMDA data going forward