We have been having a discussion regarding rounding when it comes to LTV and DTI and are in need of some guidance:

Our loan policy states for owner occupied 1-4 family 90%LTV is the maximum. We have researched FDIC Part 365 and we cannot determine if the LTV is between 90.01 to 90.49 if we can round down and not carry as a LTV exception. Is this Compliant to round down and are there any Safety and Soundness issues?

Also, our Policy for DTI states “should not exceed 42%”. Can DTI be treated the same as LTV explanation above for Compliance and Safety and Soundness?

Currently we go out 2 decimal points for LTV and DTI. If the LTV is 90.01 then we treat is as an LTV Exception. Same for DTI, if the DTI is 42.01 then we treat it as a policy exception and put it on our Fair Lending spreadsheet.

Any guidance is appreciated.

You might want to check the 90% figure again: "However, for any such loan with a loan-to-value ratio that equals or exceeds 90 percent at origination, an institution should require appropriate credit enhancement in the form of either mortgage insurance or readily marketable collateral.

Also, last I checked 42.01% exceeds 42%.

Thank you

It seems to me that there is a "rule" in mathematics that you can not create accuracy when using rounded numbers. If you are rounding income to the nearest $ 1,000, then you should not presume 0.01 accuracy in the DTI calculation. Also realize that the value is just an opinion- Is it exactly $400,000 or actually only $399.950.01?

Al