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#2167808 - 03/13/18 03:25 PM CLTV and Credit Decision
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,669
What is the general consensus (or just your understanding) for reporting the CLTV field when an LTV is used to make the credit decision, but then the loan amount or property value changes. This change doesn't impact the credit decision in any way, but would impact a straight mathematical calculation. For example, you approved a loan with an 80% LTV, then the loan amount increases a bit, making the final closed loan have an LTV of 83%. Do you report 83% for HMDA or 80%? Does the final approval basically count as the "relied on" in such a situation, because you still made the "decision" to lend at 83%.

Same thing for DTI "relied on," what if the monthly payment amount changes slightly with the final closed loan?

Thank you for your time and assistance.

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#2167817 - 03/13/18 03:34 PM Re: CLTV and Credit Decision Compliance NABW
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
I think only the underwriter/LO can answer that question. If reapproval was required, chances are the CLTV or DTI changes with that revised approval all prior to closing.

I might reconsider if they would make it regardless.
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