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#1789759 - 02/27/13 06:54 PM Income - withdrawn & files closed incompleteness
Blue78 Offline
Junior Member
Blue78
Joined: Sep 2007
Posts: 46
New England
From the GIR:

Income. Enter the gross annual income that your institution relied on in making the credit decision.

Okay….

According to an FFIEC FAQ, a satisfactory LTV is an underwriting condition. We need this condition (satisfactory LTV) met in order to make a credit decision. Following the same FAQ, we have therefore not made a credit decision if we sent a conditional approval letter requiring a satisfactory appraisal. A customer can withdraw right up to this point because a credit decision has not been made. If we receive a satisfactory appraisal and commit the loan and the customer does not close the loan we code it as approved but not accepted. We don’t code it as a withdrawal even if the customer says the otherwise magic words (“Please withdraw my loan”) because having issued the commitment letter we made a credit decision.

Following this logic, shouldn’t we code income as "NA" for all withdrawals and files closed for incompleteness because a credit decision was not made?
Last edited by Blue78; 02/27/13 06:55 PM.
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#1789996 - 02/28/13 01:27 PM Re: Income - withdrawn & files closed incompleteness Blue78
Many Hats Offline
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Joined: May 2008
Posts: 915
Orlando, FL
If you are regulated by the FDIC they want income...regardless. If you asked for it and have it, they expect to see it.

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#1790006 - 02/28/13 01:47 PM Re: Income - withdrawn & files closed incompleteness Blue78
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
And the others seem to expect it to be there as well. It is used to gauge borrower income class for fair lending purposes. NA is not useful for that.
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#1790027 - 02/28/13 02:30 PM Re: Income - withdrawn & files closed incompleteness Kathleen O. Blanchard
Blue78 Offline
Junior Member
Blue78
Joined: Sep 2007
Posts: 46
New England
Thanks for the help. I'm at HMDA overload and tired.

At least Game of Thrones returns on 3/31. So I have that going for me, which is nice.
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#1790057 - 02/28/13 03:18 PM Re: Income - withdrawn & files closed incompleteness Blue78
Indy Banker Offline
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Joined: Aug 2010
Posts: 528
Our examiners (FDIC) told us flat out if income is stated on an application or otherwise documented in file, they expect to see it on the LAR, whether the loan is originated or not. Not sure that is consistent with HUD guidance or other regulators, but that's how they interpret the instructions.

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#1790062 - 02/28/13 03:24 PM Re: Income - withdrawn & files closed incompleteness Blue78
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Our examiners (FDIC) told us flat out if income is stated on an application or otherwise documented in file, they expect to see it on the LAR, whether the loan is originated or not.

Ditto - in fact I wrote a thread (actually more of a rant) a year or so ago about how the FDIC dinged us in our exam for this issue which caused us to have to refile 3 years of LAR entries.

For the record I do not agree with the opinion but sometimes you just have to play nice. Or in this case at least pretend you are because of being overridden by the chairman of the bank.
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