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HMDA Reporting - Social Security Income

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A lender approved a mortgage loan and did not gross up the customer's social security income, so for HMDA reporting, I used what the loan officer came up with in determining his income. Now, upon reviewing my quarter-end HMDA reporting, the HMDA compliance officer claims the social security income needs to be grossed-up and that I should change my HMDA LAR to reflect this change. Is this correct? I thought that I was to report my HMDA according to the data used to approve the loan application. Please clarify this for me.

You are correct. You report the income used to make the credit decision. From page 15 of the Getting It Right Guidelines: Income of the applicant. If an application relates to a one-to-four- family dwelling, enter the total gross annual income your institution relied on in making the credit decision.

First published on 4/19/10

First published on 04/19/2010

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