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?

To me, the only differences between an LTV and a CLTV is when you have multiple collateral or multiple crossed loans affecting the 'total'. If all you have is a property and a value, your LTV IS your CLTV.

First position loans do not consider any subordinate financing. It's a non-issue.

If you have a simultaneous 1st & 2nd and you do not run the 2nd through an AUS system, do you report NA for the AUS?

If you don't use an AUS in your decision, then it does not apply. You report 6 and 17, respectively.

Ok, thanks!

What do you report for the CLTV on a HELOC loan with no initial advance?

If the Financial Institution relied on a CLTV ratio when making its credit decision, the Financial Institution reports the CLTV ratio on which it relied.

I assume that you use some sort of LTV ratio when approving the HELOC. Advances on the line or not, it would not impact the LTV used to approve the line.

And to answer this a different way....typically, you will base your HELOC 'balance' on the full possible draw amount...that's the amount you will use in your calculation. You will also take into consideration any existing first mortgage balance.

Thank you!

This may be splitting hairs but...instead of LTV and CLTV, we have a CLTV and HCLTV debate going on. Even if the investor requires that we use the HCLTV, how can we report that under CLTV? It isn't CLTV, it is HCLTV. Why wouldn't we report NA for CLTV since that isn't what we relied on in our decision?

Wanna clue us in on what a HCLTV is?

It's a Fannie Mae term (Home Equity Credit LTV). Basically, you have to consider the full amount of any line of credit on the house instead of the current balance. I'm not sure why you would ever make a credit decision on the current balance of a line and not the full amount the borrower can use, so it seems like CLTV and HCLTV should always be the same, but if you are truly only considering the current balance then I guess that would be the CLTV you report.

I'm not sure why you would ever make a credit decision on the current balance of a line and not the full amount the borrower can use

I wholeheartedly agree.

You are mixing acronyms between FNMA and HMDA, which is never a good idea.

If you are making a credit decision based on a HCLTV for FNMA - that equates to a CLTV under HMDA. It is purely the ratio upon which you are relying. How you get to that ratio is a moot point.