Historically we have created two separate LAR entry's for multiple applications on the same loan. I'm researching this position and I can't really see that this is an accurate position to have taken. Scenario: two applications were received for the purchase of an investment property. One borrower is married, but does not list spouse as an applicant, the second application includes a married applicant and spouse information. What has been done is two LAR entries, the first with the Primary and then "No Co-Applicant" is listed - the second LAR entry reflects the information that's normally reported for a joint application

I feel that answering "No Co Applicant" on the primary application is incorrect, but I don't know how else to report it.

What is the accurate way to report this loan on the LAR?
Thanks

So in your scenario, was the spouse added to the application during the application process?

No all three applicants came at the same time, primary borrower's spouse is not on any of their investment purchases.

It should be reported as one LAR entry only, with 2 GMI entries only (that's the most you can enter).

I wouldn't enter "no co-applicant" anytime i had 3 or more applicants. Pick 2 of them and report their GMI.

What has been done is two LAR entries, the first with the Primary and then "No Co-Applicant" is listed - the second LAR entry reflects the information that's normally reported for a joint application

There should have only been one entry. Each additional entry that has been made is a reporting error. See page A-6 of the GIR.

If there is more than one coapplicant, provide the required information only for the first coapplicant listed on the application form.

You had one joint loan request, the fact there were 2 applications completed for that request due to the number of applicants does not negate the above guidance.

Thank you. I received answers from my most trusted "BOLE's".

Let me add to clarify something (you may already know):
You have 2 pieces of paper called an "application", but they are not applications for HMDA (or any regulation). They are documentation of an application. IOW, you have a credit request (1) that was documented on 2 pieces of paper. Therefore, 1 LAR entry to represent THE application.