Revocable Living Trust & HMDA LAR Reporting

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Question:

An individual is the trustee of his revocable living trust and signs the security document both as the individual and as the trustee. For HMDA LAR reporting purposes can we report this loan as an applicant only type of loan because only the individual's income, credit and assets were utilized to underwrite approve the loan?

Answer:

Your post implies the individual only signed the security agreement, therefore they are not signed on the obligation and their information is not reportable. If they did sign the obligation (note) as an individual then you will report the the information for the applicant and the individual's information for the co-applicant.

First published on BankersOnline.com 5/11/09