And there should be a standard process for how it is done or the bank can end up with fair lending problems. I have seen files where there was no way to figure out how the income was arrived at...gives me pause for concern and I comment upon it.
KB, to expand on your point, I have even seen regulators start to "decide" how income calculations should have been done when a standard is lacking in a bank. When there is a standard, it is much more difficult for regulators to criticize the Bank.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com