Trying to see how others would report (or handle) DTI in the following situation:
- Borrower is an employee of the reporting bank
- Bank policy suggests that the approving loan officer would provide the monthly debts payment to HR due to confidentiality reasons.
- HR would then reference to employee income, and calculate DTI.
- HR does not provide specific DTI, but rather tells the approving loan officer, "DTI is within lending guidelines." (this is due to the LOS providing monthly debts, and one could reverse calculate to determine income).
- Approving loan officer also mentions in the comment log that "DTI is within lending guidelines."
Obviously DTI was used in the credit decision in a general sense, but it's the specific ratio is not disclosed. Would "NA" be appropriate to report, with an explanation of the procedures used?