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#1995595 - 02/12/15 04:09 PM Board Director = Employee?
Dodge Offline
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Joined: Mar 2010
Posts: 268
If a HMDA reportable loan is made to a Director, would income be reported as NA? HMDA doesn't define employee, but I would think a Director's income would be NA.

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#1995652 - 02/12/15 06:03 PM Re: Board Director = Employee? Dodge
CompBanker0613 Offline
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Joined: May 2014
Posts: 63
We report NA for income in these types of situations.
I know it's a good way for a loan to get "flagged", so to speak. I was asked about one several years ago, and explained we didn't report income because it was a board member, and they didn't have any issues/or follow-up with it.
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#1995674 - 02/12/15 06:33 PM Re: Board Director = Employee? Dodge
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,782
The Mitten State
WE have always reported the income used for the loan, until just recently. We have one employee, and not management that their income information was in a sealed and taped envelope. To each their own. This loan I reported as NA.
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#1995734 - 02/12/15 08:08 PM Re: Board Director = Employee? Dodge
Dodge Offline
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Joined: Mar 2010
Posts: 268
We have always reported NA on income when the borrower is an employee; even though, we relied on their income. However, to my knowledge, this is first time a HMDA reportable loan has came through for review on a Director. The Branch reported NA for the income. However, I didn't think a Director was considered an employee. I did email our examiner and they stated we would report the income.

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#1995736 - 02/12/15 08:12 PM Re: Board Director = Employee? Dodge
CompBanker0613 Offline
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CompBanker0613
Joined: May 2014
Posts: 63
Originally Posted By: gaints06
We have always reported NA on income when the borrower is an employee; even though, we relied on their income. However, to my knowledge, this is first time a HMDA reportable loan has came through for review on a Director. The Branch reported NA for the income. However, I didn't think a Director was considered an employee. I did email our examiner and they stated we would report the income.


Good to know. FDIC? FRB? OCC?
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"I'm not sure why they call their customers infidels, but I doubt that's important"

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#1995738 - 02/12/15 08:24 PM Re: Board Director = Employee? Dodge
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
gaints06 - I haven't seen a loan to a director in awhile, but previously I reported their income - with the exception of Executive Officer's who are directors.
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#1995816 - 02/12/15 10:19 PM Re: Board Director = Employee? Dodge
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I believe the purpose of "NA" for employees is a confidentiality issue. I've always considered it to apply to all insiders (directors, officers, employees). HMDA doesn't define an employee, but director's are paid so I think it applies. I've never heard an examiner question "NA" on any "insider".
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