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#2193360 - 09/21/18 03:55 PM Entity and Individual both Applicants
TaraTLR Offline
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Joined: May 2013
Posts: 128
I have a commercial loan that needs to be reported as a refinance for HMDA. The primary applicant is an entity and the co-applicant is the individual. Do I report the ethnicity, race and sex for the co-applicant like I normally would or do I report N/A since the loan is primarily to the entity? Do I report income? I guess any other fields that are normally N/A for entities do I report since there is an individual co-applicant? I am supper confused on this one. Any help would be greatly appreciated. Thank you.

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#2193373 - 09/21/18 04:59 PM Re: Entity and Individual both Applicants TaraTLR
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Ethnicity, Race, Sex: collect and report on the natural person. The entity would be reported as NA
Income: The reg says to report …not applicable when the applicant or co-applicant is not a natural person (e.g., a corporation, partnership, or trust). [Commentary to §1003.4(a)(10)(iii) #7]

Oddly, DTI is still required …when the applicant and co- applicant, if applicable, are not natural persons. [Commentary to §1003.4(a)(23) #5]
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David Dickinson
http://www.bankerscompliance.com

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#2198194 - 11/14/18 05:42 PM Re: Entity and Individual both Applicants David Dickinson
TaraTLR Offline
100 Club
Joined: May 2013
Posts: 128
If the DTI was not calculated for the co-borrower then do we still report N/A since it was not considered in the credit decision?

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#2198214 - 11/14/18 07:24 PM Re: Entity and Individual both Applicants TaraTLR
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Correct. But let me make sure we're talking about the exact same thing:
If the first applicant is an entity and the second applicant (co-applicant) is a natural person; and
If you didn't calculate/use a DTI for that natural person; then
You report NA.
_________________________
David Dickinson
http://www.bankerscompliance.com

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