We denied a loan to a borrower because he is unemployed and has 0 income. Clearly income was considered. So NA doesn't seem appropriate. But we cannot report 0 for a HMDA loan. Thoughts?

It doesn't look like the GIR guide addresses borrower's with no income. I would reach out to your regulator or HMDA Help to get a ruling.

I was able to locate a potential answer for you based on what I see as a similar question. The answer appears to be to report NA due to input limitations. However, this answer is from 2012 so perhaps things have changed?

https://www.bankersonline.com/qa/how-report-negative-income-hmda-lar

I think sort of by definition, if you have zero income, it's NA......as if you literally have no money coming in, that "amount" isn't "income". You don't have an income....zero dollars isn't "income".

Thank you all very much for your responses!

I would use NA for someone without income. In the revised Commentary, the instructions are to use NA if you are relying on asset depletion (such as liquidation of securities or savings) for repayment rather than income.

You can't rely on income that does not exist.

This has always been a problem and discussed before. I've had examiners tell me tor report "1" for income, but I disagree. You should be able to report "0" in this case. Since that isn't possible, I would also report "NA". Document why.

We have been told by our examiners to use "1" for loans with negative income, but not for "0". I did email HMDA Help before I posted on here. But I never receive responses back from them so I'm not holding my breath!