Denial Reasons - Revised HMDA

When reporting denial reasons under the new (final) HMDA rule, the ( #9) reporting code for denial reasons is used to report a denial reason of "OTHER" . We have multiple denial reasons that fall under the category of : ( #9-Other) that can be reported in the FREE TEXT box on the LAR.

Question:
If more than one denial reason (under the OTHER category) is applicable, which of the Denial Reason would we report in the FREE TEXT form box on the LAR? Do we only show the 1st one ; are we required to show all of the reasons (separated by a comma) ?

I'm not aware of any specific guidance on this. The regulation requires we report the principal reasons - up to 4. If you have more than 1 "other", I believe you would need to report them all (not stop at 1). There are 255 characters allowed in the text field. I don't know if you would put a comma, semi-colon or what to separate them.

I thought about this some more. Quite honestly, we might not know the answer until we can use the software and see how to handle this. It could be that you enter each "Other" separately, selecting code 10 for each. Not sure.