I believe I can report NA for income for applications coded as withdrawn or closed for incompleteness, since no income was "relied upon" since there was "no credit decision" made. This is my preference, as it's one less field to have a possible error.

Do others report this way?

We report the income listed on the application.

"NA" is a red flag, but not necessarily wrong in all cases. Just because it was withdrawn or closed for incompleteness doesn't mean the loan officer didn't evaluate the income. I think marking the income field on all withdrawals/incompletes will get you a violation.

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UGH, what a nightmare Dan!! Ok, I perhaps can see if we started underwriting on an application, that ended up being cancelled as incomplete (after sending incomplete notice) that perhaps income was being considered.

But for us, we don't sell on secondary market, so don't have DU/LP. And for loans we code as withdrawn, there has been truly NO underwriting, and possibly not complete collection of documentation. Our policy is if we pull a credit report, we have an application (we don't have prequals per se.)

So if a borrower writes he makes $xx annually on his financial statement, and withdraws a few days later, I'm still inclined to put NA in income.

But I think the best answer is to check with my FDIC examiners... I'll post what they say. So if anybody else is reporting NA for income on withdrawn applications, I'd love to hear, thanks.