HMDA Reporting for Loans Processed by CUSO

Question - My credit union is around $160 million in assets. We have been collecting Home Mortgage Disclosure Act (HMDA) information and reporting it for years. We have a credit union service organization (CUSO) that contains a mortgage company. It is my understanding it must also be collecting and reporting HMDA information. Does it matter that the CUSO does not actually make the decisions or retain the loans that are funded? It processes the loan application, but another company approves or declines the loan and funds it. The CUSO handles all the paperwork but finds someone else that books the loans. Is the CUSO required to report HMDA information?

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