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HMDA: More than 2 applicants/borrowers

Question: 
When I have three co-borrowers made up of two LLCs and one person, how do I enter that on the LAR?
Answer: 

You only report information for the first two borrowers. Which borrowers you report is up to you; however, I would go with the order they are listed on the note. For example if the note lists the borrowers as LLC #1, LLC #2 and then John Doe, you would report the GMI using the codes for “n/a” for both the borrower and co-borrower on the HMDA-LAR. You would still collect GMI for John Doe; you just won’t report it on the HMDA-LAR.

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First published on 02/07/2016

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