HMDA-Business income used for credit decision

Loan to an individual for consumer purpose. The loan officer is indicating that they did not use the individual's income to determine credit decision, but instead, underwrote the loan based on the income of the borrower's business. My question is do we report the income from the business as that was what was used for the credit decision, or do we report NA since we did not take the borrower's income into consideration when making the credit decision.

Business 'income' is revenue. If he's not reporting income on his personal tax returns from the business net revenue, then I'd say 'income' was not considered.

Curious as to other responses.

I may be all wet on this one, but to me.............if the LO conjures up some number from a deck of UNO cards and qualifies the borrower based on that, that's the "income" that was "used" in making the credit decision, and i would report that number.

Since the business does not appear to be a borrower (and I am assuming the business is not a sole proprietorship) how does this loan officer expect to collect payment from the business' revenue if the borrower fails to pay?

Also, if this loan is subject to ATR and/or QM qualifications were the Reg. Z ATR guidelines and/or Appendix Q followed for verifying the borrower's income and ATR?

If the bank looked at business cash flow to see what was available for the owner to take and used that, it is not "income". So I think you could justify NA. If they drilled down to what he took from the business to pay his bills, that is income to him.

I am taxed on LLC profit whether I took it or not.

Thank you all for your responses. I'll have to dig a little deeper on the ATR situation. For some reason I am thinking this might be commercial purpose to an individual borrower.