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#2190961 - 08/28/18 11:28 PM No income listed on application
larmanini Offline
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Joined: May 2018
Posts: 30
Hi

I have several loan applications whre the loan officer did not obtain income and the loan is either withdrawn or cancelled do to incompleteness. Do I report this loan on the LAR?

Also theloan is not an FHA Streamline or VA IRRRL.
Last edited by larmanini; 08/28/18 11:40 PM.
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#2190972 - 08/29/18 12:25 PM Re: No income listed on application larmanini
Adam Witmer Offline
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Posts: 2,662
Do you mean they hadn't yet obtained income and therefore did not have an "application" under TRID (meaning that an LE was not yet provided)?

What do you consider to be an application for HMDA/Regualtion B purposes?
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#2191016 - 08/29/18 03:02 PM Re: No income listed on application Adam Witmer
larmanini Offline
Junior Member
Joined: May 2018
Posts: 30
If they have all six peices of required information with the exceptions of FHA Streamine and VA IRRRLS/

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#2191250 - 08/30/18 04:41 PM Re: No income listed on application Adam Witmer
larmanini Offline
Junior Member
Joined: May 2018
Posts: 30
so would I report a loan that does not have income on the HMDA LAR? With the exception of FHA Streamlines and VA IRRRLs.

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#2191922 - 09/07/18 03:26 PM Re: No income listed on application larmanini
larmanini Offline
Junior Member
Joined: May 2018
Posts: 30
Any takers on this question? If there no income listed and it was not used to decision the loan do I report it on the LAR?

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#2191937 - 09/07/18 05:10 PM Re: No income listed on application larmanini
RVFlyboy Offline
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RVFlyboy
Joined: Oct 2000
Posts: 5,991
Soaring over Georgia
If you considered it to be an application without income, then you obviously didn't rely on any income in processing the application at the time the application was withdrawn or the file closed for incompleteness. Per 1003.4(a)(10)(iii) and comment 4(a)(10)(iii)-5 and the FIG, I think you would report NA for that field.
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#2191941 - 09/07/18 05:42 PM Re: No income listed on application larmanini
raitchjay Offline
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Joined: Oct 2009
Posts: 9,111
OK
FWIW, i agree.
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