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#2218337 - 07/24/19 06:20 PM Loan to non-natural person and individual
complyorelse Offline
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Borrowers are a corporation and an individual. I want to be sure I am interpreting the commentary correctly when it comes to reporting the demographic information, age, and income. In summary, the commentary states that if the borrower or co-borrower is not a natural person that we would report NA. Does that mean that I report NA for both of them or just in the fields specific to the non-natural person? I have always thought that it meant for both of them, but am second-guessing myself since this is not something we run across a lot.

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#2218341 - 07/24/19 06:55 PM Re: Loan to non-natural person and individual complyorelse
complyorelse Offline
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Adding to my question, the credit score and DTI state to report NA when the borrower AND co-borrower are not-natural persons. So I do have to report those fields?

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#2218351 - 07/24/19 07:44 PM Re: Loan to non-natural person and individual complyorelse
Mountaineers_Fan Offline
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Joined: Jun 2018
Posts: 94
My understanding is that you'd report age and demographic information for the natural person and NA for the non natural.

Income and DTI are NA.

Credit Score would be reported for the natural person IF you relied on it in making the credit decision.

I look at it this way, there are two age fields, two demographic fields but only one income and DTI.

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#2218549 - 07/26/19 05:18 PM Re: Loan to non-natural person and individual complyorelse
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
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Central City, NE
I agree with Montainneers except:
DTI - you must report. The Commentary to §1003.4(a)(23) #5 says to report “N/A” …when the applicant and co- applicant, if applicable, are not natural persons.
That's not your case.
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David Dickinson
http://www.bankerscompliance.com

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#2218570 - 07/26/19 08:02 PM Re: Loan to non-natural person and individual complyorelse
Mountaineers_Fan Offline
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Posts: 94
David you're absolutely correct on the DTI.

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#2219010 - 08/02/19 04:08 PM Re: Loan to non-natural person and individual complyorelse
complyorelse Offline
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We calculate a DSCR for commercial loans, not DTI. So am I okay reporting NA for DTI since we don't calculate it for commercial loans? The commentary states that NA is appropriate for DTI if it is not calculated.

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#2219014 - 08/02/19 04:24 PM Re: Loan to non-natural person and individual complyorelse
Melissa S Offline
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Melissa S
Joined: Jan 2015
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Maine
Complyorelse,

I deal with HMDA only for commercial loans and I do exactly that: DTI is NA as we do not calculate nor rely on DTI in decision making. We use DSCR as well.
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#2219070 - 08/02/19 08:29 PM Re: Loan to non-natural person and individual complyorelse
complyorelse Offline
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Joined: Nov 2007
Posts: 442
U.S.
Thanks so much.

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