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#2196705 - 10/29/18 05:01 PM Business/Individual Age and Income
Cat Lover Offline
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Joined: Jun 2016
Posts: 147
I have loan with a borrower being a business entity and the co-borrower an individual. Do I report the age for the individual and for income is it N/A or the amount that it was relied on for the credit decision? Thank you.

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#2196876 - 10/30/18 09:02 PM Re: Business/Individual Age and Income Cat Lover
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Income: If either of the applicants is a business, income is NA [Commentary to §1003.4(a)(10)(iii)(#7)]. The wording in the commentary says "when the applicant or co-applicant is not a natural person . . ."

Age: I understand you are to report the age of all natural persons that apply. Therefore, you would give the DOB of the co-borrower. [Commentary to §1003.4(a)(10)(ii)(#4)]

The wording in the Commentary cited is the same ("applicant or co-applicant"). Last year, I wrote the CFPB and asked if "or" meant "if either is a non-natural person are we to report NA?" The CFPB replied that ethnicity, race, sex and age are always reported for people. Income is always NA if there's a entity involved.
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David Dickinson
http://www.bankerscompliance.com

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