Hello - Our LAR software (QuestSoft) is generating V655-1 on a particular file we have.
It says if GMI of borrower is NA then income must be NA as well.

In this particular situation, our primary applicant is an entity (so its GMI is all "NA"), and our co-applicant is an individual (so his GMI is completed with his selections - and yes I'm sure he's a co-applicant - I'm sure he's not a guarantor only).
Our loan officer confirms the co-applicant's income was indeed relied upon for the credit decision, so we reported that income on the LAR as well.

QuestSoft references me to the HMDA FIG under V655.

I tried to contact CFPB but their Reg Inquiries is down - at least for me anyway.

Any help? Thanks in advance.

Reg. C says to report NA when the applicant or co-applicant is a non-natural person, so i'm with QuestSoft on this.

7. Income data—non-natural person. A financial institution reports that the requirement is not applicable when the applicant or co-applicant is not a natural person (e.g., a corporation, partnership, or trust). For example, for a transaction involving a trust, a financial institution reports that the requirement to report income data is not applicable if the trust is the applicant. On the other hand, if the applicant is a natural person, and is the beneficiary of a trust, a financial institution is required to report the information described in § 1003.4(a)(10)(iii).

Hmmm, never read it that literal before (they say "or" instead of "and"). Maybe that's how the old reg read as well, but I know the FFIEC (back when they ran the HMDA show) actually had us change our LAR and said if the primary applicant or the 1st co-applicant was an individual then we DO report income.
Therefore I carried that instruction over into 2018.
So this is new to us. Ugh. Time for a scrub on those commercial HMDA files.

FOLLOW-UP question now...
DTI field does NOT have the same guidance in the FIG.
DTI Official Interpretations is almost opposite of OI for the Income field.
1003.4(a)(23) OI-5 specifically says when the applicant AND co-applicant are not natural persons.
In our situation only the applicant is not a natural person. So it seems (per the illogical/inconsistent interpretations) that we would still report DTI, even if they are saying income is "NA".??

Then i believe you would just go back to:

4. Transactions for which no debt-to-income ratio was relied on. Section 1003.4(a)(23) does not require a financial institution to calculate the ratio of an applicant's or borrower's total monthly debt to total monthly income (debt-to-income ratio), nor does it require a financial institution to rely on an applicant's or borrower's debt-to-income ratio in making a credit decision. If a financial institution made a credit decision without relying on the applicant's or borrower's debt-to-income ratio, the financial institution complies with § 1003.4(a)(23) by reporting that the requirement is not applicable since no debt-to-income ratio was relied on in connection with the credit decision.

If you relied on a DTI ratio, you'd report it. If you didn't, you'd put NA.

Yep. Thanks for sharing your thoughts on this! How confusing. Luckily 'most of the time' our entity loans have the actual individual as a guarantor and not a co-applicant/borrower.

Happy HMDA everybody :\