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#2165112 - 02/19/18 04:03 PM Business Income
BOTO67 Offline
New Poster
Joined: Mar 2010
Posts: 15
Arkansas
What are others reporting for income on business purpose loans where the underwriter or LO did not use gross annual income in making the credit decision? Do you take what is disclosed for the income they used, or do you actively search for the gross annual income?

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#2165137 - 02/20/18 01:32 PM Re: Business Income BOTO67
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
I report whatever it is they used, or didn't use.
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#2165141 - 02/20/18 01:57 PM Re: Business Income BOTO67
Adam F Offline
Gold Star
Adam F
Joined: Apr 2013
Posts: 420
VA
We do the same as Joker.
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The answers I give are my opinions. Not legal advice.

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#2165167 - 02/20/18 04:39 PM Re: Business Income BOTO67
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I agree. You shouldn't try to guess. The LO/Underwriter should be telling you what they used for income. Otherwise, your system is set to fail.
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David Dickinson
http://www.bankerscompliance.com

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#2165361 - 02/21/18 08:00 PM Re: Business Income BOTO67
Bbgreen Offline
Member
Joined: Jan 2014
Posts: 76
Texas
We are creating procedures to avoid future inconsistencies on what income is reported. If the loan is over a certain amount we will use a large line review, if it falls under the said amount we will have an income analysis.

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#2166194 - 02/28/18 06:54 PM Re: Business Income BOTO67
BOTO67 Offline
New Poster
Joined: Mar 2010
Posts: 15
Arkansas
I agree that we should take what they use, but the rule states that you must use the gross annual income used in making the credit decision. What if they didn't use gross annual income, instead used net income or cash flows?

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#2166197 - 02/28/18 07:02 PM Re: Business Income BOTO67
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
If net - Use what they relied upon. That's what Joker, NSF and I have consistently stated above.
If cash flows - there is a lot of debate whether this is "income". You can search here and find many discussions on this.
_________________________
David Dickinson
http://www.bankerscompliance.com

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