For HMDA reportable employee loans we report NA for the income to help keep income confidential. We would also like to keep credit scores confidential. Do the rules allow banks to report NA or 8888 for credit score on employee loans?

Unfortunately, the rules do not provide an exception for credit scores. Therefore, credit scores must be reported (as applicable) for employee loans. The same is true for the DTI of an employee loan.

Adam's right. This one burns my butt. The CFPB recognized the need for confidentiality when reporting income, but somehow lost their logic when it came to DTI and credit score. I wrote the CFPB about this when the regulation was proposed and again after it was finalized. Nothing changed.

Well, one thing about DTI is that you wouldn't be able to back into the income amount anyway because you would have to know about the person's debts as well.

I don't imagine they thought about it much at all...since the income was already allowed to be omitted from way back or always. When the new data points were created, no thought was given to those areas. Now that income is not so protected anymore, it may be a matter of time before that allowance goes away...who knows.