Board Director = Employee?

If a HMDA reportable loan is made to a Director, would income be reported as NA? HMDA doesn't define employee, but I would think a Director's income would be NA.

We report NA for income in these types of situations.
I know it's a good way for a loan to get "flagged", so to speak. I was asked about one several years ago, and explained we didn't report income because it was a board member, and they didn't have any issues/or follow-up with it.

WE have always reported the income used for the loan, until just recently. We have one employee, and not management that their income information was in a sealed and taped envelope. To each their own. This loan I reported as NA.

We have always reported NA on income when the borrower is an employee; even though, we relied on their income. However, to my knowledge, this is first time a HMDA reportable loan has came through for review on a Director. The Branch reported NA for the income. However, I didn't think a Director was considered an employee. I did email our examiner and they stated we would report the income.

Good to know. FDIC? FRB? OCC?

gaints06 - I haven't seen a loan to a director in awhile, but previously I reported their income - with the exception of Executive Officer's who are directors.

I believe the purpose of "NA" for employees is a confidentiality issue. I've always considered it to apply to all insiders (directors, officers, employees). HMDA doesn't define an employee, but director's are paid so I think it applies. I've never heard an examiner question "NA" on any "insider".