I am probably overthinking this, so please help. We are relying on an LTV on all loans and I cannot believe the CFPB does not want to know that # so I am inclined to report the LTV in the CLTV field. See below.
Our LOS does not calculate a CLTV in the situation where there is only 1 loan; it only calculates an LTV. Are you reporting the LTV as the CLTV in this case?
Secondly, I am being told we only care about the existence of another lien if we are in 2nd lien position. If we are in first lien position, we don't care and are not calculating a CLTV, only an LTV based on our loan and the property value. Following the above logic, do I then report the LTV because I am relying on an LTV in my credit decision or do I report NA as the CLTV?