I've searched this and still don't have a good answer. We have a borrower that is a Trust. There are also two co-borrowers on the note. I understand that I need GMI information on the co-borrowers and should report it on the lar for one of the co-borrowers. However, I'm stumped on income. Do I put N/A or do I use the co-borrower's income that was used to underwrite the note. Previous threads have mixed answers. Some help is appreciated!

In my shop, I report those as NA as the applicant (Trust) is not a natural person. Just went through an OCC exam that looked at our HMDA with no issues.

We don't report the income and this is why in Reg C:

Appendix A, 6 Income, d:

If the applicant or co-applicant is not a natural person...enter "NA".

I agree. The income is used to identify low-moderate incomed individuals. It would only apply to a natural person.

What if the borrower and first co-borrower are individuals and the second co-borrower was the trust? Still NA?

A co-applicant is a co-applicant, regardless of how many there are.

7. Income data—non-natural person. A financial institution reports that the requirement is not applicable when the applicant or co-applicant is not a natural person (e.g., a corporation, partnership, or trust). For example, for a transaction involving a trust, a financial institution reports that the requirement to report income data is not applicable if the trust is the applicant. On the other hand, if the applicant is a natural person, and is the beneficiary of a trust, a financial institution is required to report the information described in § 1003.4(a)(10)(iii).