[gllewis]

If we have two borrowers, one is a natural person and the other is not a natural person, do we still report GMI, age and credit score on the natural person and NA for the non-natural person?

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[jholzknecht]

You are on the right track, but it is not simple. If an applicant is not a natural person you report:
– Ethnicity as Code 4
– Race as code 7
– Sex as code 4
– Age as code 8888
– Income as not applicable
– Credit score as code 8888.

[gllewis]

OK for not natural person.. I get that, but what about the natural person…. do we enter their Age, Income and Credit Score? It seems like I read that we would not.

[jholzknecht]

Regulation C is not clearon this point. The HMDA Small Entity Compliance Guide states. that NA is reported for:
– age if the applicant is not a natural person.
– the income if the applicant or co-applicant, is not a natural person.
– the credit score if the applicant and co-applicant, if applicable, are not natural persons.

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