1) We did a work out refinance loan where customers have a negative income. I tried to enter as 0 on the LAR and it wouldn't take it, so I put in a NA. It is showing up on my edit. What should I use for the income???

2) We did a refinance of a huge farm with a residence on it and participated out a portion of the loan. I reported it. Loan amount is $1,350,000. It shows 13500 as loan amount on my edit and says loan amount is over $2 million so I must have too many zeros in there and it is taking loan amount as $13,500,000.
My questions are: Is this HMDA reportable and how do I enter a loan amount of that size.

1--Your getting a quality edit. Those are just flagged to make sure that's what you want to put. I would put NA (negative income probably didn't really have any say in your credit decision).

2--You have too many zeros. Re-enter it as 1350.

1. How can some one have a negative gross income? Their expenses may have exceeded the income therefore showing a loss, but they did not have a negative gross income. You report the gross income relied on in the credit decision. If they had a gross income of $100,000 and $110,000 in expenses they showed a loss of ($10,000) however the $100,000 was the gross income used to arrive at you income available for debt service.

Page 15 of the GIR:

Income of the applicant. If an application relates to a one-to-four- family dwelling, enter the total gross annual income your institution relied on in making the credit decision. . .

Perhaps, in the workout situation, there was no income at all but there were expenses and the borrower drew on existing cash to cover those expenses. "Gross" income would still be 0, deducting expenses paid would create net income.

Dan, we get that all the time for CRA when the borrower is a non-profit organization. For income, the officer will write a zero and then the words "non-profit organization." I mean seriously!!! These people are lenders and don't know the difference between income and profit?

I think part of the problem is the way the government throws terms around that do not relate to reality. They talk about gross revenue (sales) but then say to use the revenue number used in the bank's credit decision. Well, sales are not used in the credit decision (except for judging is the company making sales, is it growing, shrinking, etc.) In the debt service calculation for a credit decision, you use profit.

They don't help the situation.

You should be able to enter a HMDA-reportable loan that size. It's reportable. I guess you should call your software company or are you entering directly into the FFIEC software? We gather our information in a separate software and then download to the FFIEC software for reporting.

Oh I see, Kathleen!!! Defend the lenders!!!

My good deed for the day. I used to be a lender!

What Q number is the over 2 million edit?

Q002 is one of them. Open the FFIEC software and click on the Help button and then go to Editing Options and About Errors, in that section you will find Error Messages for 2009.