Skip to content
BOL Conferences
Thread Options
#544635 - 05/08/06 07:22 PM Employee Income HMDA
Sound Tactic Offline
Power Poster
Sound Tactic
Joined: Feb 2005
Posts: 5,349
I have a closed loan to an employee on our LAR. We traditionally do not put any income onto our database for fear others will see how much they make. But the LAR says NA for income. As I read page A-7 of the "Guide" I see no references to NA being anything other than multifamily dwellings, corporations or loans where no income was used in making the credit decisions.

I think the employee should have listed the income on the LAR. Does this sound accurate?

Thanks
_________________________
If your tagline references disclaimers regarding the nature of political posts, then you should just hit notify.

Return to Top
Lending Compliance
#544636 - 05/08/06 07:30 PM Re: Employee Income HMDA
Pepper's Sister Offline
Platinum Poster
Pepper's Sister
Joined: May 2005
Posts: 546
Midwest
Ii believe that the GIR (and the Reg) allow for NA for employee loans.
_________________________
I wouldn't have missed it for the world.

Return to Top
#544637 - 05/08/06 07:37 PM Re: Employee Income HMDA
Sound Tactic Offline
Power Poster
Sound Tactic
Joined: Feb 2005
Posts: 5,349
Thank you, I did not ever think I would find an answer to a HMDA question in the reg. From Appendix C:

8. Income data—loan to employee. An institution may report “NA” in the income field for loans to its employees to protect their privacy, even though the institution relied on their income in making its credit decisions.
_________________________
If your tagline references disclaimers regarding the nature of political posts, then you should just hit notify.

Return to Top
#2058808 - 01/14/16 09:54 PM Re: Employee Income HMDA Sound Tactic
3up3down Offline
Junior Member
Joined: Jun 2008
Posts: 25
We had an employee that closed a HMDA reportable loan last January. We posted her income as NA but she has since left the bank's employment. Should I now modify the entry to state the income we relied upon?

Return to Top
#2058810 - 01/14/16 09:57 PM Re: Employee Income HMDA Sound Tactic
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
I wouldn't. She was an employee when the loan was originated and I would leave it at that.
_________________________
My Opinions Only

Return to Top
#2058811 - 01/14/16 09:57 PM Re: Employee Income HMDA Sound Tactic
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
OK
Agree with Skittles.
_________________________
I'm fixin' to fix that.

Return to Top
#2058812 - 01/14/16 09:59 PM Re: Employee Income HMDA Sound Tactic
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,650
Florida
I would not, assuming you do not do it for all. Assuming it was her sole income, it would reflect the pay for the position.
See above citation by sound tactic - consistancy is important ad she was an employee when the loan was made..
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#2059225 - 01/19/16 02:45 PM Re: Employee Income HMDA Sound Tactic
Cheli Offline
Platinum Poster
Cheli
Joined: May 2013
Posts: 919
MY FI does not go back and change the LAR...

Return to Top
#2059232 - 01/19/16 02:59 PM Re: Employee Income HMDA Sound Tactic
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Do not go back and change it. It was an employee loan at the time it was made.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#2071880 - 03/31/16 05:06 PM Re: Employee Income HMDA Sound Tactic
complyorelse Offline
Gold Star
Joined: Nov 2007
Posts: 448
U.S.
Is N/A an option if the employee applied jointly with another person? There is nothing in the commentary or anywhere else that I could find that addresses this. I believe N/A would be the correct choice but am not 100% certain.
Thank you.

Return to Top
#2071887 - 03/31/16 05:25 PM Re: Employee Income HMDA Sound Tactic
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
OK
Yes, if any of your applicants are employees, you can use N/A for income.
_________________________
I'm fixin' to fix that.

Return to Top
#2071891 - 03/31/16 05:30 PM Re: Employee Income HMDA Sound Tactic
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
OK
Look at it this way: is the loan to an employee? Yes. The fact that 1 or 2 or 8 other people on the loan are not employees doesn't negate the fact that one of them is. That's why you don't see any clarification of it in the commentary.
_________________________
I'm fixin' to fix that.

Return to Top
#2071892 - 03/31/16 05:38 PM Re: Employee Income HMDA Sound Tactic
complyorelse Offline
Gold Star
Joined: Nov 2007
Posts: 448
U.S.
Thank you.

Return to Top

Moderator:  Andy_Z