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#1345709 - 02/18/10 09:17 PM Withdrawn Application w/no income
In Need of Help 101 Offline
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Application was dropped off by applicant. Failed to complete the income section. After multiple failed attempts to contact the applicant by the loan officer to obtain this information, she finally reaches him but he decides to withdraw the application. No income information was ever obtained.

Can I use "NA" for the income? The GIR refers to if no income info is asked for or relied on in the credit decision enter "NA"...actually we never made a credit decision though.

We did happen to have a previous loan on this individual in 2006 where income was shown. The loan officer did refer to the old information and assumed that the applicant made at least the same amount if not more than in 2006.

Would it be better to use the income from 2006???

HELP!!!

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#1345720 - 02/18/10 09:25 PM Re: Withdrawn Application w/no income In Need of Help 101
RolTyde Offline
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Anywhere but here
Is it a completed application without the income? At my bank, it's not and we would not report since there is no application.

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#1345757 - 02/18/10 09:58 PM Re: Withdrawn Application w/no income RolTyde
hmdagal Offline
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We would report NA.

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#1346910 - 02/22/10 03:44 PM Re: Withdrawn Application w/no income hmdagal
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Between the lines
When did you get the app? According to the new rules in July, income is a required component to be considered an application. Maybe you do not have an app for HMDA reporting.
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#1346923 - 02/22/10 03:57 PM Re: Withdrawn Application w/no income SMQ, CRCM
Truffle Royale Offline

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Most importantly, no, you don't take information from a previous application to complete this one. Each application should be treated as a stand alone document.

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#1346937 - 02/22/10 04:12 PM Re: Withdrawn Application w/no income SMQ, CRCM
hmdagal Offline
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Originally Posted By: SoccerMomQueen
When did you get the app? According to the new rules in July, income is a required component to be considered an application. Maybe you do not have an app for HMDA reporting.


Weren't those Reg Z rules? I don't think they have a direct impact on HMDA reporting.

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#1346947 - 02/22/10 04:21 PM Re: Withdrawn Application w/no income hmdagal
Kathleen O. Blanchard Offline

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If you determine you have a reportable application, I would report as NA. You report the "withdrawn" code as your action taken and NA is allowed for actions where income was not relied upon.
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#1346974 - 02/22/10 04:42 PM Re: Withdrawn Application w/no income Kathleen O. Blanchard
Dan Persfull Offline
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Bloomington, IN
The income being a requirement of an application is a new RESPA requirement and I agree with hmdagal, that has no impact on it being an application (203.2(b)) for HMDA reporting purposes.

FWIW we report NA for income on all withdrawn applications. There was no credit decision made therefore there was no income used.
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#1347278 - 02/22/10 10:45 PM Re: Withdrawn Application w/no income Dan Persfull
Lissa P. Offline
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Joined: Oct 2003
Posts: 474
Texas, USA
Good point, Dan. Wished I had thought of that one...

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