I'm reviewing an originated commercial loan for HMDA, and trying to see how others would report DTI in this situation. Here are some details:

- The borrower is an individual (guarantors are the borrower's various businesses)
- The loan analysis used is a global analysis in which it has both he individual's income and cashflows from the businesses.
- A DTI is showing on the analysis, but it looks like the debt is accounting for both personal and business debts. So the DTI calculated is showing < 70%.
- Comments in the analysis are referring to the DSCR figures for strong cash flows and repayment of the loan.

While DTI is calculated, DSCR seems to be "relied on" in this situation; thus, it would be reasonable to report DTI as NA? It seems that reporting DTI of 70% would raise some concerns when the LAR is being reviewed.

We report NA in these situations, as long as it's clear the underwriting is based on DSCR and not DTI.

As do we. I think there is a pretty solid argument that the "DTI" you describe is not a "DTI" as defined in the regs as it includes debts that are not the borrowers, but regardless, if it's not relied on it can be NA.

4. Transactions for which no debt-to-income ratio was relied on. Section 1003.4(a)(23) does not require a financial institution to calculate the ratio of an applicant's or borrower's total monthly debt to total monthly income (debt-to-income ratio), nor does it require a financial institution to rely on an applicant's or borrower's debt-to-income ratio in making a credit decision. If a financial institution made a credit decision without relying on the applicant's or borrower's debt-to-income ratio, the financial institution complies with § 1003.4(a)(23) by reporting that the requirement is not applicable since no debt-to-income ratio was relied on in connection with the credit decision.