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#470978 - 12/15/05 08:50 PM HMDA Income - App Withdrawn
Suzie Offline
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Suzie
Joined: Apr 2002
Posts: 662
Far North
No income is listed on loan application but file indicates appliant's employment and income were verified by lender.

Even though no income is listed on original loan app, shouldn't the vierifed income amount be listed on the LAR for this withdrawn application?

Thanks -
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Lending Compliance
#470979 - 12/15/05 08:59 PM Re: HMDA Income - App Withdrawn
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,535
Bloomington, IN
We report NA for withdrawn applications. If the application was withdrawn then there was no credit decision, therefore there was no income used in a credit decision.
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#470980 - 12/15/05 09:54 PM Re: HMDA Income - App Withdrawn
Suzie Offline
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Suzie
Joined: Apr 2002
Posts: 662
Far North
Thanks Dan.

So, in all instances if an application is withdrawn you report income as NA?
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#470981 - 12/16/05 02:25 PM Re: HMDA Income - App Withdrawn
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,535
Bloomington, IN
Yes, as long as the application was withdrawn before a credit decision was made.

The Reg. requires you to report the gross annual income used in making the credit decision. If the applicant withdraws before a credit decision is made then how could income have been used in a credit decision. There was no credit decision.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#470982 - 01/05/06 10:04 PM Re: HMDA Income - App Withdrawn
JSD Offline
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JSD
Joined: Oct 2000
Posts: 512
USA
Dan, In following this thread, I am curious as to when entering NA for the income on the W/D loans, doesn't this create some type of Quality Check Error? This would be great as long as it does not add to the research time. Thanks

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#470983 - 01/06/06 02:05 PM Re: HMDA Income - App Withdrawn
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,535
Bloomington, IN
It will give a quality check error. However, all action codes are going to be 4s, therefore if your LAR is showing an action code 4 you know it was a withdrawn and that's the reason for the NA in the income field.
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The opinions expressed are mine and they are not to be taken as legal advice.

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