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#2155828 - 12/03/17 03:20 AM CLTV - Didn't round but is 80.0
Likes to Comply Offline
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In the mountains
CLTV is always calculated to one decimal place for credit approval at our FI. So if it happens to be a whole number, it would still be noted as 80.0 on a write up for credit approval. Would we report it with one decimal place 80.0 or as 80 for HMDA.

FIG -
Enter, as a percentage, the ratio of the total amount of debt secured by the property to the value
of the property relied on in making the credit decision. Use decimal places only if the ratio relied
upon uses decimal places.
Example: If the relied upon combined loan-to-value ratio is 80.05, enter 80.05, and not 80.
If, however, your institution rounded the ratio down to 80 and relied on the rounded-down
number, enter 80.
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#2189920 - 08/21/18 04:02 PM Re: CLTV - Didn't round but is 80.0 Likes to Comply
RVFlyboy Offline
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Soaring over Georgia
Bump. This never got an answer but curious if someone has an "official" interpretation on this. For CLTV that calculates to a whole number percentage, do we report just the whole number or do we add 1, 2, or more zeros after the decimal? FIG is unclear.
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#2189929 - 08/21/18 04:33 PM Re: CLTV - Didn't round but is 80.0 Likes to Comply
David Dickinson Offline
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Central City, NE
I understand your issue and can only render a guess. The bottom line is the FIG is unclear. I'd email the CFPB and ask them to clarify.
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#2189941 - 08/21/18 05:19 PM Re: CLTV - Didn't round but is 80.0 Likes to Comply
RR Joker Offline
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The Swamp
It always seemed clear to me. There are no trailing zero's here.

Example: If the relied upon combined loan-to-value ratio is 80.05, enter 80.05, and not 80.
If, however, your institution rounded the ratio down to 80 and relied on the rounded-down number, enter 80.
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#2189954 - 08/21/18 05:55 PM Re: CLTV - Didn't round but is 80.0 RR Joker
RVFlyboy Offline
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Soaring over Georgia
Originally Posted By RR Joker
It always seemed clear to me. There are no trailing zero's here.

Example: If the relied upon combined loan-to-value ratio is 80.05, enter 80.05, and not 80.
If, however, your institution rounded the ratio down to 80 and relied on the rounded-down number, enter 80.
Where do you see any documentation that says there are no trailing zeros? FIG just says this: Example:
80.05 (or) NA. The small entity compliance guide, nor the regulation and commentary, nor the Getting it Right guide say anything about decimals or trailing zeros.
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#2189958 - 08/21/18 06:01 PM Re: CLTV - Didn't round but is 80.0 Likes to Comply
RR Joker Offline
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RR Joker
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The Swamp
That came out of the FIG page 83
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#2189959 - 08/21/18 06:02 PM Re: CLTV - Didn't round but is 80.0 Likes to Comply
RR Joker Offline
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RR Joker
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The Swamp
correction, page 82.
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#2189966 - 08/21/18 06:17 PM Re: CLTV - Didn't round but is 80.0 Likes to Comply
RVFlyboy Offline
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RVFlyboy
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Soaring over Georgia
Sure enough. OK, that makes it clear for me too. Thanks for the heads up.
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#2189996 - 08/21/18 07:56 PM Re: CLTV - Didn't round but is 80.0 Likes to Comply
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
Anytime, Beech!
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