We made a credit decision, declining a loan after the employment verification determined the borrower was not working and not generating income.

The decision was based on $00.00 income. Our HMDA software does not accept $00.00 as income, it defaults to N/A instead,.

It may be a matter of interpretation; however, I can't see how N/A is applicable under these circumstances, nor can I report the income initially reported, because the loan was denied for no income. I welcome your perspectives.

Thank you

I know there was inititially an argument that income could only be a positive or negative integer (which leaves out poor little 0) based on a validity error, but I was pretty sure that had been debunked. The wording of the validity error is still misleading, but I know we submitted some with 0 income without it triggering. I'd talk to your HMDA Software rep. We would report $0. I would argue N/A is incorrect.

I'm watching this thread. We use third party software to retain our HMDA LAR and had a very similar situation like this last week - and we're receiving a validity error.

The preamble to the 2017 final HMDA amendments:

"Finally, the Bureau notes that the 2015 HMDA Final Rule and the 2018 FIG do not include any language that would bar a financial institution from reporting an applicant's gross annual income as “0” or even a negative number when that is the accurate figure that it relied on."

I'm curious as to whether the CFPB considers 0 a negative or positive integer, but putting that aside, it seems pretty clear to me. You can report $0.

We reported 0 for a number of loans with that same situation last year. I would talk to your software provider.