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credit score & DTI for employee applications

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  • March 18, 2019 at 5:22 pm EDT #14655
    TheBank
    Participant

    For HMDA reportable employee applications, we report NA for the income to help keep income confidential. Can we report NA for DTI and credit scores on employee applications as well?

    March 21, 2019 at 5:02 pm EDT #14673
    rcooper
    Member

    Regulation C commentary to 1003.4(a)(10) allow banks to report NA for income on employee loans. However, neither the regulation nor the commentary provide the same exception for DTI at 1003.4(a)(23) or Credit Score at 1003.4(a)(15).

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