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#544635 - 05/08/06 07:22 PM Employee Income HMDA
Sound Tactic Offline
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Sound Tactic
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I have a closed loan to an employee on our LAR. We traditionally do not put any income onto our database for fear others will see how much they make. But the LAR says NA for income. As I read page A-7 of the "Guide" I see no references to NA being anything other than multifamily dwellings, corporations or loans where no income was used in making the credit decisions.

I think the employee should have listed the income on the LAR. Does this sound accurate?

Thanks
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Lending Compliance
#544636 - 05/08/06 07:30 PM Re: Employee Income HMDA
Pepper's Sister Offline
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Midwest
Ii believe that the GIR (and the Reg) allow for NA for employee loans.
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#544637 - 05/08/06 07:37 PM Re: Employee Income HMDA
Sound Tactic Offline
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Thank you, I did not ever think I would find an answer to a HMDA question in the reg. From Appendix C:

8. Income data—loan to employee. An institution may report “NA” in the income field for loans to its employees to protect their privacy, even though the institution relied on their income in making its credit decisions.
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#2058808 - 01/14/16 09:54 PM Re: Employee Income HMDA Sound Tactic
3up3down Offline
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Joined: Jun 2008
Posts: 25
We had an employee that closed a HMDA reportable loan last January. We posted her income as NA but she has since left the bank's employment. Should I now modify the entry to state the income we relied upon?

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#2058810 - 01/14/16 09:57 PM Re: Employee Income HMDA Sound Tactic
Skittles Offline
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TN
I wouldn't. She was an employee when the loan was originated and I would leave it at that.
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#2058811 - 01/14/16 09:57 PM Re: Employee Income HMDA Sound Tactic
raitchjay Offline
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OK
Agree with Skittles.
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#2058812 - 01/14/16 09:59 PM Re: Employee Income HMDA Sound Tactic
Rocky P Online
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Florida
I would not, assuming you do not do it for all. Assuming it was her sole income, it would reflect the pay for the position.
See above citation by sound tactic - consistancy is important ad she was an employee when the loan was made..
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#2059225 - 01/19/16 02:45 PM Re: Employee Income HMDA Sound Tactic
Cheli Offline
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Cheli
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MY FI does not go back and change the LAR...

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#2059232 - 01/19/16 02:59 PM Re: Employee Income HMDA Sound Tactic
Kathleen O. Blanchard Offline

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Do not go back and change it. It was an employee loan at the time it was made.
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#2071880 - 03/31/16 05:06 PM Re: Employee Income HMDA Sound Tactic
complyorelse Offline
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Joined: Nov 2007
Posts: 442
U.S.
Is N/A an option if the employee applied jointly with another person? There is nothing in the commentary or anywhere else that I could find that addresses this. I believe N/A would be the correct choice but am not 100% certain.
Thank you.

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#2071887 - 03/31/16 05:25 PM Re: Employee Income HMDA Sound Tactic
raitchjay Offline
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OK
Yes, if any of your applicants are employees, you can use N/A for income.
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#2071891 - 03/31/16 05:30 PM Re: Employee Income HMDA Sound Tactic
raitchjay Offline
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Look at it this way: is the loan to an employee? Yes. The fact that 1 or 2 or 8 other people on the loan are not employees doesn't negate the fact that one of them is. That's why you don't see any clarification of it in the commentary.
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#2071892 - 03/31/16 05:38 PM Re: Employee Income HMDA Sound Tactic
complyorelse Offline
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U.S.
Thank you.

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