When it comes to interpreting the HMDA requirements, the words “and” and “or” can make a big difference. Thus, it’s important to pay close attention to not only the Regulation and Commentary but also to other resources, such as the Filing Instructions Guide. A couple of examples for where this comes into play are with the Income data field and the Monthly Debt-to-Income Ratio data field. More specifically, what to report for each field when you have an applicant or applicants that are not natural persons.
Published
2021/04/20