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#2217633 - 07/15/19 03:29 PM Income and DTI
Lizard60 Offline
New Poster
Joined: Oct 2018
Posts: 22
Ky
We have a customer that we were going to do a loan for, income was verfied, however right towards the end, he lost his job.
Adverse Action Letter states 'unverifiable info'.

We are unsure how to report the income and DTI. Do we go ahead and report what we originally had as the income and DTI and with it being unverifiable info that would explain that we couldn't verify his income? Or do we need to have income state -0-?

Appreciate your help!

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#2217652 - 07/15/19 04:44 PM Re: Income and DTI Lizard60
Kimo in Idaho Offline
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Joined: Jun 2019
Posts: 135
What income amount did you use in making the decision. It sounds to me like you used the customer's income as stated to you, but couldn't confirm the customer's employment. If that is the case I would report what was stated to you.

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#2217669 - 07/15/19 06:12 PM Re: Income and DTI Lizard60
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
You said you were GOING TO do a loan. I assume you are denying the request now. Why? Because he lost his job. That makes his income $0 and you're relying on that deny the request. IF I have that right, I would report the income as $0 and DTI as $0. The $0 income is what led to your FINAL decision - the one you are reporting on the HMDA LAR.

If you reported the origianl income, but send an AAN saying the loss of the job led to the denial, I think your LAR entry has conflicting info.
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#2217995 - 07/18/19 08:39 PM Re: Income and DTI Lizard60
Kimo in Idaho Offline
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Joined: Jun 2019
Posts: 135
I agree, with David that it does depend on what you stated was the reason for denial. So go back to that and make your determination.

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#2218781 - 07/30/19 07:28 PM Re: Income and DTI Lizard60
scb2011 Offline
100 Club
Joined: Mar 2011
Posts: 239
TN
I have a related question. If we deny based on delinquent past or present credit obligations with others from the credit report, can we report income as $0?

(Income was not used to make the credit decision. The lender did not list the income on the application)

Or do I need to get the lender to include income on the application so that it is reported?

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#2218799 - 07/30/19 08:35 PM Re: Income and DTI Lizard60
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,568
OK
If you didn't rely on income, report NA.
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#2256683 - 07/14/21 04:56 PM Re: Income and DTI Lizard60
Red Raiders Offline
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Red Raiders
Joined: May 2013
Posts: 1,053
Compliance Land
We denied an application because of bad credit. No income was listed on the application. I assume this gets reported as NA for Income and NA for DTI but wanted to make sure. Thoughts?
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