Posted By: Mel in WA
CLTV - Commercial Decline - 01/24/20 08:38 PM
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 For an Application that was withdrawn before a credit decision was made (even if a CLTV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.
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 For an Application that was withdrawn before a credit decision was made (even if a CLTV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.