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#2231057 - 02/14/20 03:55 PM Applicant becomes employee after loan
TMatt87 Online
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TMatt87
Joined: May 2011
Posts: 1,984
Idaho
We originated a HMDA loan in early 2019 to an individual who later in the year became an employee. Since the borrower was not an employee at the time of application, we reporter her income. Now that I'm getting ready to report, I'm wondering if I should, or am able to report NA as she is now an employee.
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#2231067 - 02/14/20 04:58 PM Re: Applicant becomes employee after loan TMatt87
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Whoever actually has the ability see the information has already seen it, have they not?
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#2231076 - 02/14/20 06:04 PM Re: Applicant becomes employee after loan rlcarey
Carolina Blue Offline
Platinum Poster
Carolina Blue
Joined: Jul 2005
Posts: 960
Lost in a regulatory fog
I see where you may be concerned from a consistency standpoint, but the applicant was not an employee at the time of the loan so I don't think you can report as NA. The purpose of that exemption option is to help reporters maintain some salary confidentiality. In your case the applicant's income has nothing to do with their new salary at your bank.

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