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#1982208 - 12/10/14 06:36 PM Income for HMDA-Reportable Farm Refinance
NMB Offline
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Southeast Michigan
If we have a farm/ag HMDA-reportable refinance, to a natural person, that is also a CRA-reportable small farm, how do you calculate the gross income for HMDA?

For the CRA-reportable loan I have gross revenue, based on the farm-related revenue. Should the same amount be reported as HMDA gross income? Or should there be a separate calculation based on consumer income sources. Somehow it seems like the same income/revenue should be used for both, but I can't find any guidance or previous threads.
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#1982216 - 12/10/14 06:50 PM Re: Income for HMDA-Reportable Farm Refinance NMB
raitchjay Offline
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I don't believe there's anything in Reg. C or the GIR that will tell you *how* to calculate the income; it simply states to report the income "used" in making the credit decision. As far as i can tell, the how's and why's are left up to the bank.
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#1982350 - 12/10/14 11:07 PM Re: Income for HMDA-Reportable Farm Refinance NMB
CompBanker0613 Offline
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You can't double report this Ag Refi.
You will only want to report it under HMDA.
Is the loan in the name of a business, like Hobbs Farm LLC? Or is to John Smith? If it's to a business then you can use NA for income, but if it's to an individual I would use your normal procedure as far as what you use for income, whether it be tax returns or what the lender used to decision the loan, etc.
Last edited by CompBanker0613; 12/10/14 11:08 PM.
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#1982353 - 12/10/14 11:27 PM Re: Income for HMDA-Reportable Farm Refinance NMB
NMB Offline
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Southeast Michigan
It is okay to double count a refinance of a farm loan that includes a farm house, for CRA large bank data collection and for HMDA. (See the CRA Q and A's of 2012: §ll.22(a)(2)—7.)

It has just been one of those days when I doubted the way I have looked at income/revenue in those situations.
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#1982356 - 12/10/14 11:50 PM Re: Income for HMDA-Reportable Farm Refinance NMB
CompBanker0613 Offline
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What Q & A are you referring to?
I'm aware of the one from March 2010 and the update in November 2013
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#1982357 - 12/10/14 11:57 PM Re: Income for HMDA-Reportable Farm Refinance NMB
CompBanker0613 Offline
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What Q & A are you referring to?
I'm aware of the one from March 2010 and the update in November 2013
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#1982445 - 12/11/14 03:56 PM Re: Income for HMDA-Reportable Farm Refinance NMB
NMB Offline
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Southeast Michigan
Sorry, I meant the March 2010 Q & A.
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#1982453 - 12/11/14 04:06 PM Re: Income for HMDA-Reportable Farm Refinance NMB
CompBanker0613 Offline
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Thank you. We don't view the dwellings we take as collateral as an "abudance of caution", so we generaly report our Ag Refi (with dwellings) for HMDA purposes.
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