DTI for loans to entities

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Question:

For loans to entities (LLC, Corporation, Trust, etc), if the lender calculated a DTI (along with a DSC - debt service coverage ratio), do we report the DTI for HMDA?

Answer:

Report NA for DTI on loans to entities.

Sec. 1003.4(a)(23) Debt to Income

5. Non-natural person. A financial institution complies with § 1003.4(a)(23) by reporting that the requirement is not applicable when the applicant and co-applicant, if applicable, are not natural persons.

There is no equivalent exclusion for reporting LTV/CLTV for loans to entities. (1003.4(a)(24))

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