The following information is from the recent HMDA Small Entity Compliance Guide about reporting CLTV. It's very clear in number 2-4 when to use "NA". My question is about number one. If the lender did not calculate the LTV and the application was denied for credit history or income/cash flow, should we be entering "NA" or calculating the CLTV based on information on the application/in the file?

A Financial Institution reports that this data point is not applicable:

1. If it did not rely on a CLTV when making the credit decision;
2. If the Application file was closed for incompleteness (even if a CLTV ratio was
calculated);
3. For an Application that was withdrawn before a credit decision was made (even if a CLTV
ratio was calculated); or
4. For a purchased Covered Loan. Comments 4(a)(23)-3 through -5.

If it wasn't calculated, then it would be pretty hard to rely on it.

If the credit decision for your borrower was made before the LTV was calculated, which means your institution did not rely on that calculation in making the decision, you would report "NA"