I have been reading through some of the older posts where the HMDA income is zero and what to report for the DTI. In some of the other posts it was recommended to report income and DTI as zero = 0. We have four denied loans where the borrower applied with no income so far this year. Our Mortgage department and underwriting dept. is thinking since they are unable to calculate the DTI in their credit decision we should report the DTI as NA - not used in the credit decision and not use zero for the DTI. How is everyone else reporting this on their HMDA LAR? Any information would be greatly appreciated. Thanks, Lisa

To add more information to my question from yesterday. The loan purpose is purchase and the borrower stated income in the application of $7500.00 monthly. In DU income was entered as 0 and DU returned DTI of 0.00%.The underwriter added comments on the 1008 transmittal summary that the borrower is on administrative leave from employment new/additional employment is only temporary/supplemental and he has no history of working in this industry. Application shows this is a new job as of October 2022 and income is $7500 monthly. The denial reason is due to length of employment and temporary or irregular employment. We reported zero income and DTI on the HMDA LAR record based on what DU returned. I just want to confirm this is correct since the borrower stated income in the loan application and we reported zero income and zero DTI. Thanks.

The following cites are from the August 2023 FIG.

Paragraph 4(a)(10)(iii)—Income.
Enter, in dollars, rounded to the nearest thousand, the gross annual income relied on in making
the credit decision, or if a credit decision was not made, the gross annual income relied on in
processing the application (round $500 up to the next $1,000). The HMDA Platform can accept
negative numbers for Income.

Appears $0 income was the amount used in making the credit decision.


(2-80) Paragraph 4(a)(23)—Debt-to-Income Ratio.
Enter, as a percentage, the ratio of the applicant’s or borrower’s total monthly debt to the total
monthly income relied on in making the credit decision. Use decimal places only if the ratio
relied upon uses decimal places. The HMDA Platform can accept up to 15 decimal places and
can accept negative numbers for Debt-to-Income Ratio.

In this case the applicant's debt divided by $0 would equal 0%.

I don't recall seeing any guidance that prohibits reporting 0 as the DTI.

Thank you so much Dan. I was afraid that no one was going to give me their opinion on this. Thanks again. I appreciate the response.