We have a loan that closed under two business entities, however the owners signed the promissory note as individuals as well. We show Co #1, Co.#2 and the two individuals signing as well. There are items in the new HMDA that if applicant and co-applicant are not individuals you can report N/A. What happens in a situation like this one. The LE, CD and all other documents are drafted as business entities.

Who applied for the loan and if the individuals did not apply, how are they on the loan? Why would an LE/CD ever be issued to a business entity?

They got an application for the both entities and the owners of each, at closing the promissory note is signed as Managing Member of the each of the entities and as individuals. Looks like they will be using the property as a second home.

You need to make a determination if this is a consumer loan or a business loan. In the beginning (your original post) made it sound like this was a business purpose loan to two businesses & 2 individuals additionally signed the loan. However, if you issue LE/CD, it makes it sound like a consumer purpose loan. So which is it?

Without knowing this, we can't advise you on the "NA" questions you have with HMDA.

Did the individuals 'sign' as borrowers or as guarantors?

I went to the mortgage and it's listing one of the company's and the two that signed as individuals. I tend to go by reporting all four in HMDA, two entities and the two individuals. As far as income, the new 2018 HMDA indicates to report NA for applicants/co-applicants that are not individuals, I have a mix. Should I report the income taken into the account for the approval process? Thank you.

If any borrower is an entity, income will be NA.