HMDA Multiple borrowers

How are multiple borrowers treated for HMDA and where can I find information addressing this.

Could you explain a little more what you're looking for, please? I don't quite understand what you mean by 'treated'.

If I have 4 borrowers on one mortgage how many are required to be on the HMDA LAR

Only two; however you must collect the monitoring information from all 4.

Remember that it's the application that is reported on the LAR, not the borrowers. With that being said, if there are more than 2 applicants, you would collect GMI for all of them, and report the information for the first 2 on your LAR. Income should be reported for all applicants.

From HMDA GIR

c. If there is more than one co-applicant, provide the required information only for the first co-applicant listed on the application form. If there are no co-applicants or coborrowers, use Code 5 (for ethnicity) and Code 8 (for race) for “no co-applicant” in the coapplicant column.

Thanks everyone

How would you report the monitoring for a joint application that was originally denied, then re-opened after removing one of the applicants, and was again denied? An adverse action was sent to both applicants originally, and again to the single applicant. Would you report monitoring for both applicants, or only the single applicant from the final action?

That's a new application and should be a separate LAR entry.

Does anyone agree that it should be two separate applications, even though only one application was entered?

How would you report the monitoring for a joint application that was originally denied, then re-opened after removing one of the applicants, and was again denied?

Did you treat them as separate applications or did you treat the second application as a continuation of the original application? See page D-7 of the GIR.

FWIW we use to treat these as one application but for tracking purposes we now treat them as separate applications and report both.

We treated the second application as a continuation of the original application. We are reporting the monitoring for both applicants as they originally applied jointly. Thanks Dan for your response.