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!!!

Is it a completed application without the income? At my bank, it's not and we would not report since there is no application.

We would report NA.

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.

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.

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

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 You report the "withdrawn" code as your action taken and NA is allowed for actions where income was not relied upon.

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FWIW we report NA for income on all withdrawn applications.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.

Good point, Dan. Wished I had thought of that one...