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#2229634 - 01/24/20 08:38 PM CLTV - Commercial Decline
Mel in WA Offline
Diamond Poster
Joined: Mar 2013
Posts: 1,171
The following information is from the recent HMDA Small Entity Compliance Guide about reporting CLTV. It's very clear in number 2-4 when to use "NA". My question is about number one. If the lender did not calculate the LTV and the application was denied for credit history or income/cash flow, should we be entering "NA" or calculating the CLTV based on information on the application/in the file?

A Financial Institution reports that this data point is not applicable:

1. If it did not rely on a CLTV when making the credit decision;
2. If the Application file was closed for incompleteness (even if a CLTV ratio was
3. For an Application that was withdrawn before a credit decision was made (even if a CLTV
ratio was calculated); or
4. For a purchased Covered Loan. Comments 4(a)(23)-3 through -5.

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#2229637 - 01/24/20 09:35 PM Re: CLTV - Commercial Decline Mel in WA
Inherent_Risk Offline
Gold Star
Joined: Jan 2017
Posts: 363
If it wasn't calculated, then it would be pretty hard to rely on it.

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#2229655 - 01/27/20 01:15 PM Re: CLTV - Commercial Decline Mel in WA
Melissa S Offline
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Melissa S
Joined: Jan 2015
Posts: 305
If the credit decision for your borrower was made before the LTV was calculated, which means your institution did not rely on that calculation in making the decision, you would report "NA"
Expect the worst, hope for the best and you'll never be disappointed.

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