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.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com