Question: If a commercial officer uses net income to underwrite the loan, should we report Net Income instead of Gross Income on the HMDA-LAR?
Answer: While the regulation specifies “gross” annual income, it goes on to say, that is relied on in making the credit decision…We believe you should report the income that is used in the credit decision, even if it is not gross. Thus, you should report the net income since that is what the loan officer used.
Published
2019/09/19
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