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#2206160 - 02/14/19 05:17 PM Credit Score as N/A on withdrawals with no Co-app
TaraTLR Offline
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Joined: May 2013
Posts: 136
I have a question about reporting NA for the credit score and Version on a withdrawn application when there is no co-applicant.

We ran the LAR through the platform to check for errors. It came back with 3 errors on withdrawn files where there was no co-applicant. It indicated that we should report 8888 for the credit score and 9 for the version. The reference chart in the HMDA Getting it Right Guide says you report 9999 when there is no co-applicant and 10 for the version.

I know the guidance says that if the file is withdrawn prior to a credit decision being made that you report NA for the applicant or co-applicant. So does the 9999 only apply if the file has an action taken code of 1-3 and 7 & 8?

Your opinions would be greatly appreciated.

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#2206216 - 02/14/19 07:39 PM Re: Credit Score as N/A on withdrawals with no Co-app TaraTLR
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,622
Look at validity edit V664 from the Filing Instruction Guide (FIG):

1) If Action Taken equals 4, 5, or 6, then Credit Score of Applicant or Borrower must equal 8888 or 1111; and Applicant or Borrower, Name and Version of Credit Scoring Model must equal 9 or 1111; and Applicant or Borrower, Name and Version of Credit Scoring Model: Conditional Free Form Text Field for Code 8 must be left blank.

From the commentary:
Commentary
4. Transactions for which no credit decision was made. If a file was closed for incompleteness or the application was withdrawn before a credit decision was made, the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant. For example, if a file is closed for incompleteness and is so reported in accordance with § 1003.4(a)(8), the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant. Similarly, if an application was withdrawn by the applicant before a credit decision was made and is so reported in accordance with § 1003.4(a)(8), the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant.


and...
6. Purchased covered loan. A financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable when the covered loan is a purchased covered loan
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#2206429 - 02/16/19 04:40 PM Re: Credit Score as N/A on withdrawals with no Co-app TaraTLR
HMDA Warrior Offline
Junior Member
Joined: Jan 2018
Posts: 48
I have asked this question multiple times throughout the year and I have gotten consistent guidance in the later part of the year.

If the Action Taken is 4 or 5, then the applicant and co-applicant credit score and scoring model is to be reported as not applicable (8888 and 9) regardless of whether or not there is a co-applicant. The commentary is not clear about whether or not there is a co-borrower, but the Validation Edit is more clear.

Validation Edit 664 does refer to the co-applicant, the note above only refers to the applicant or borrower:

An invalid Credit Score data field was reported.
Please review the information below and update your
file accordingly.

1) If Action Taken equals 4, 5, or 6, then Credit Score
of Co-Applicant or Co-Borrower must equal 8888 or
1111; and Co-Applicant or Co-Borrower, Name and
Version of Credit Scoring Model must equal 9 or
1111; and Co-Applicant or Co-Borrower, Name and
Version of Credit Scoring Model: Conditional Free
Form Text Field for Code 8 must be left blank

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#2207967 - 03/06/19 06:31 PM Re: Credit Score as N/A on withdrawals with no Co-app TaraTLR
TaraTLR Offline
100 Club
Joined: May 2013
Posts: 136
Does this same philosophy apply to age. If the loan or adverse file is to an entity and there is no co-applicant do we report 8888/N/A for the age or 9999 for no co-applicant.

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#2208055 - 03/07/19 12:54 PM Re: Credit Score as N/A on withdrawals with no Co-app TaraTLR
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,622
If there is no co-applicant, you report 9999 (No co-applicant) for age.

From the commentary to the HMDA age requirement:
"2. Applicant data—co-applicant. If there are no co-applicants, the financial institution reports that there is no co-applicant."[/]

Also, the FIG says this:
[i]"b. Use Code 9999 in the co-applicant field if there are no co-applicants or coborrowers."
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2265201 - 01/25/22 10:17 PM Re: Credit Score as N/A on withdrawals with no Co-app TaraTLR
Jgmez Offline
New Poster
Joined: Jan 2022
Posts: 1
Does anyone know what type of purchaser code we report on purchaser type (HMDA LAR) when an investor becomes ineligible for the loan program?

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#2265202 - 01/25/22 10:20 PM Re: Credit Score as N/A on withdrawals with no Co-app TaraTLR
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,727
OK
Not sure i understand the question. You either sell the loan or you don't. If an investor isn't eligible or for whatever reason won't purchase the loan, then how/why does the affect the entity you ultimately DO sell the loan to? Or if you end up keeping the loan in your portfolio, then you would report a "0".
Last edited by raitchjay; 01/25/22 10:22 PM.
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