HMDA Reporting - Social Security Income

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Question:

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.

Answer:

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 BankersOnline.com 4/19/10