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#1489814 - 01/05/11 04:15 PM Another HMDA ??
gunches Offline
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I have a loan on rental property where there are 3 borrowers. How do I enter this on the LAR? Do I combine all 3 incomes?

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#1489826 - 01/05/11 04:29 PM Re: Another HMDA ?? gunches
idabanker Offline
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Posts: 16
We would combine all three incomes and our application software does the same.

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#1489833 - 01/05/11 04:36 PM Re: Another HMDA ?? idabanker
gunches Offline
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Posts: 210
What do you use for race, ethnicity, sex. I have 2 males and 1 female

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#1489873 - 01/05/11 05:12 PM Re: Another HMDA ?? gunches
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,661
Originally Posted By: gunches
I have a loan on rental property where there are 3 borrowers. How do I enter this on the LAR? Do I combine all 3 incomes?
The Getting It Right guide states you should use the income you used to underwrite the loan. If you used all three incomes, use that. If just one, use that.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#1489875 - 01/05/11 05:15 PM Re: Another HMDA ?? gunches
Adam Witmer Offline
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Joined: Sep 2010
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Originally Posted By: gunches
What do you use for race, ethnicity, sex. I have 2 males and 1 female
The Getting It Right guide Appendix A, Section D.4.c states:

"If there is more than one co-applicant, provide the required information only for the first co-applicant listed on the application form."
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#1489879 - 01/05/11 05:23 PM Re: Another HMDA ?? gunches
idabanker Offline
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Joined: Mar 2008
Posts: 16
If it's not a natural person (llc, corp etc,) then put NA. I think you just have to choose two since that is all the LAR entry will accommodate and I don't think you can make separate LAR entries in this circumstance. You could base your decision on which two have the greatest interest, or the first two that applied, if applications were taken on different days.

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#1489916 - 01/05/11 05:50 PM Re: Another HMDA ?? idabanker
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,661
Originally Posted By: idabanker
I think you just have to choose two since that is all the LAR entry will accommodate and I don't think you can make separate LAR entries in this circumstance. You could base your decision on which two have the greatest interest, or the first two that applied, if applications were taken on different days.


Be careful when you start to "think" about HMDA. Rather, I would follow the Getting It Right Guide to a "T". HMDA CMP's are up significantly right now and this is a real "hot topic."
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#1490319 - 01/05/11 11:08 PM Re: Another HMDA ?? Adam Witmer
SMQ, CRCM Offline
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Between the lines
idabanker, don't take this wrong but HMDA doesn't always make sense. It's a govt regulation, emphasis on govt. LOL just kidding I have been caught too many times trying to make a logical decision, it really doesn't work.

We use App 1 and App 2 for HMDA reporting, GMI, etc. Like AJ said, income is the income you relied on, maybe all 3, or maybe you only considered income of App 1 and App 3. If so, you still show App 1 and 2 on report, but income for App 1 and 3.
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#1490360 - 01/06/11 12:10 AM Re: Another HMDA ?? SMQ, CRCM
GottaLuvHMDA Offline
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Joined: Feb 2010
Posts: 65
WA/OR
I had an examiner tell me once - "when it comes to HMDA; you take what makes sense - then do the opposite." :-) That was the year we remnamed the acronym to: Has Mistakes. Do Again. :-)
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