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#2166111 - 02/28/18 12:45 AM Director Income
Moman Offline
Platinum Poster
Joined: Jul 2004
Posts: 505
WA
I have searched all the CFPB references, including the master of all - the new Getting It Right Guide, and only found "employees" when referencing waiving the requirement to collect income. Has anyone out there seen similar language anywhere for Directors? I searched +income +director on BOL and came up empty. Without any language relating to Directors, I will be reporting income for this - hate to, but guess that it will need to be reported.

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#2166115 - 02/28/18 12:12 PM Re: Director Income Moman
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,583
HMDA does not define an "employee," but since a director is paid by the bank, I have seen where banks have listed director income as NA without being criticized by an examiner. As "employee" is not defined, you will find that there will be two different approaches to this. I would just choose an approach and be consistent.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2166150 - 02/28/18 04:31 PM Re: Director Income Moman
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,455
Bloomington, IN
Previous Discussion

We report NA for employees and directors.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2166239 - 02/28/18 09:36 PM Re: Director Income Moman
Moman Offline
Platinum Poster
Joined: Jul 2004
Posts: 505
WA
OK - Y'all swayed me. Appreciate the info, as always.

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#2174757 - 04/23/18 08:35 PM Re: Director Income Moman
Frank Ernest Offline
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Joined: Nov 2004
Posts: 138
Somewhere on a beach
We have a Securities company that is not part of the bank but is a subsidiary of the holding company. We have a loan to an employee of the Securities company. The 2018 rules require that we report NA for income of the institution's employee. Is an employee of the Securities company also an employee of the bank for income reporting purposes?

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