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#2213875 - 05/17/19 02:18 PM DTI for HMDA
Krit Offline
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Joined: Jan 2017
Posts: 4
Good morning - I'm curious as to what DTI you are using to report on the LAR. Is it the U/W DTI or the final DTI at closing (with the correct PITI). I've read the guidelines and I know its credit decision but most systems are built to have a fluid DTI based on the changes to the payment, etc.

Sorry if this was asked previously but I couldn't locate it.

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#2213892 - 05/17/19 03:02 PM Re: DTI for HMDA Krit
Inherent_Risk Offline
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Joined: Jan 2017
Posts: 570
"I've read the guidelines and I know its credit decision"

I don't think the reg cares too much how most systems are built. If you can defend stating that the "final DTI" in the system is the DTI you "relied on in making the credit decision" then you can report it, but if you made your credit decision based on a different DTI, then the reg is pretty clear.

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#2214079 - 05/21/19 03:59 PM Re: DTI for HMDA Krit
swiggles Offline
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swiggles
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I have a similar problem. We have a relatively small LAR. We cannot import from either software use for our Mortgage Docs (LaserPro and Calyx Point). So we have resorted to complete manual entry. Each banking center is responsible for submitting their loan file documents to our imaging system.....so you can imagine the mess. When I am looking through files, I sometimes find 3 or 4 different Closing Disclosures and have to make sure I am looking at the final disclosure when entering data. Several reportable data points come from Point's "Loan Transmittal Summary" document. Sometimes, I find two or three of those. I can tell when one isn't the final one because, for example, the appraised value doesn't match what the appraisal indicates. I have been making sure that I have the final version, even if I have to ask the Lender to image it. So.....even though the DTI and appraised value (therefore CLTV) might not be what we considered when making the credit decision, at least I am reporting everything the same for every borrower.....rather using a Final Summary for one and a Not Final Summary for another.

That's kind of long and drawn out, but I am very interested in feedback, advice, ideas, etc.
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#2214096 - 05/21/19 05:41 PM Re: DTI for HMDA Krit
MScarn6942 Offline
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Posts: 756
Land Lacking in Lakes, IL
Krit and Swiggles, what are you using to document your credit decision and the information you relied on to make it? An application? 1008? DU/LP? That'd be a way to input your DTI at the point in time you made your credit decision.
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#2214104 - 05/21/19 06:51 PM Re: DTI for HMDA MScarn6942
swiggles Offline
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swiggles
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Posts: 7,351
Quote:
what are you using to document your credit decision and the information you relied on to make it? An application? 1008? DU/LP? That'd be a way to input your DTI at the point in time you made your credit decision.


That would take more useless, unfollowed training. Sometimes I see one AUS result which might not have passed. And then the Transmittal Summary.

Multiple AUS, multiple Loan Transmittal Summaries, multiple Closing Disclosures. Whatever is in the software electronically or elsewhere and whatever is paper, is thrown into the imaging system.
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#2214258 - 05/23/19 01:30 PM Re: DTI for HMDA MScarn6942
Krit Offline
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Joined: Jan 2017
Posts: 4
We use the 1008 and/or DU depending on the product. However, the DTI in the system updates as we update the final payment for closing. Therefore, we have to manually review the source document with the data for the LAR. We are putting a new field in place but its a manual entry - it will be the credit decision DTI.

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#2214446 - 05/28/19 07:15 PM Re: DTI for HMDA Krit
clinds Offline
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Joined: Sep 2017
Posts: 66
We use the 1008 Transmittal; however, I'm not sure that is accurate because the credit decision in my mind is based on the underwriting (DU/LP). Are there issues if we consistently use the 1008 and it does not match the underwriting (DU/LP) occasionally due to something changing?

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#2214464 - 05/28/19 09:09 PM Re: DTI for HMDA clinds
swiggles Offline
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swiggles
Joined: Aug 2001
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Quote:
We use the 1008 Transmittal; however, I'm not sure that is accurate because the credit decision in my mind is based on the underwriting (DU/LP). Are there issues if we consistently use the 1008 and it does not match the underwriting (DU/LP) occasionally due to something changing?

I would be interested in reading any input on this.
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#2214469 - 05/28/19 10:00 PM Re: DTI for HMDA Krit
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 1,984
Idaho
We use the 1008 because that's where the income we based our decision is. There are occasionally minor changes that require an updated AUS report, but don't get sent back through full underwriting, so we don't consider our decision to be based on the amended figures. However, significant changes require the file to be re-underwritten and will result in an updated 1008. We just use the most recent 1008 in those cases.
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#2214481 - 05/29/19 12:56 PM Re: DTI for HMDA Krit
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
In the 1008's Underwriter's Comments section our underwriter explains how they calculated the income and that is what we use.
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#2247263 - 01/06/21 04:58 PM Re: DTI for HMDA Dan Persfull
Comply 101 Offline
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Comply 101
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Jumping on this question again about 1008 not matching AUS/DU input information. Has anyone been criticized by auditor/examiner because the 1008 will say they relied on DU #8 for approval, but DU #8 has a slightly different DTI then the 1008. We are consistent in reporting information from the 1008.
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