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HMDA Income and 1-4 Loan

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Question: 
Should the income provided by a guarantor used in connection with a 1-4 loan (eg: "Dad") be included for HMDA purposes?
Answer: 

No

HMDA GIR
Appendix D, Page D-12
6. Income data—income relied on.

Appendix D An institution reports the gross annual Official Staff income relied on in evaluating the Commentary on creditworthiness of applicants. For Regulation C example, if an institution relies on an applicant’s salary to compute a debt- to-income ratio but also relies on the applicant’s annual bonus to evaluate creditworthiness, the institutionreports the salary and the bonus to the extent relied upon. Similarly, if an institution relies on the income of a cosigner to evaluate creditworthiness, the institution includes this income to the extent relied upon. But an institution does not include the income of a guarantor who is only secondarily liable.

First published on BankersOnline.com 6/6/11

First published on 06/06/2011

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