My bank originates secured home improvement loans under the FHA Title One program. This FHA program requires no equity and no appraisal. On the Loan Estimate and Closing Disclosure for such loans, we do insert a very rough estimate for the property value. However, value and CLTV is not used in making the credit decision.

For a loan like this, do we report Property Value and CLTV as NA?

Thanks all!

You would report NA. I would prepare a document explaining the program, why you calculate a rough estimate, and clear statements of howmthe credit decision is made, and that value and cltv are not relied upon.