For the first time, we purchased loans in 2002. (Not the servicing, the loans are ours.) So this is my first time reporting purchases on my HMDA LAR.

I can omit certain data such as race, sex and income. The seller provided us with some of this data, however. As an example, I have the borrowers race and sex, but not the co-borrower's. It is appropriate to report what I have, which could be misleading as it would appear there were no co-borrowers, or should I "NA" all of it, or is it purely optional?

I believe you have the option. However, if you choose to report the info, I would suggest information not provided for the co-applicants instead of not applicable.

Page C-4 of GIR

(b)(2) Race or national origin, sex and income data may but need not be collected for:

(i) Loans purchased by the institution; or

ditto on dpersfull, this is how we report purchased loans

In reply to:

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I would suggest information not provided for the co-applicants instead of not applicable.

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But page 27 of GIR says that NA would be the appropriate codes, not that it wasn't provided.

That said, I have not reviewed all these files and would have a lower error rate if I "NA"d everything possible. Wouldn't this be the smarter move, albeit with less data to work with?

Andy, if you're not going report any of the information then I agree that NA should be reported.

My thought was based on if you were going to report the info you have on the borrower, then I was suggesting info not provided for the co-borrower instead of NA.

We NA. It's safer and should save you hours of work on data integrity.

I opted for the NA as well, where I could enter it. Time efficient, perfectly allowable and less risk when reviewed. These were not LMI loans meant to add to CRA so there is no need to brag on them.

Incomes seem to allow NA, but it could be read as conditional if it has been collected.
"Enter “NA” if your institution does not take the applicant’s income into account, or if the loan or application is for a multifamily dwelling, or if you choose not to collect this information for a purchased loan."

Is there a problem with the file having the income, but me "NA"g the LAR?

I'd go with the NA even if the information is in the file Andy. The GIR states that You may, but need not, report race, national origin, sex and gai for loans purchased....then offers the NA option. Without being directed specifically otherwise by the regulators, I'd keep it consistent and NA across the board.

That's just my opinion in reading the GIR manual...and you know I wear duct tape to formal events so take it for whatever it's worth

For what it's worth, I agree. If you have the out, why go to all the time and trouble to review the files and then possibly have input errors?