[tgerst]

I am currently trying to do the HMDA reporting for a VA loan.

The loan amount via the Note is $63333.00…this includes the VA funding fee, but it is the whole amount that the customer financed because it’s the amount on the Note.
So I feel we need to report this loan amount.

BUT, in doing this, the appraised value of the property is $62,000.
So when reporting the CLTV, it’s over 100% so I get an error on my HMDA software.

The DO/DU show the CLTV as 100% because for VA loans you qualify for the loan without including the VA funding fee.

So I guess what I’m asking:
Do we report the loan amount that shows on the Note (legal obligation)….and then still have the CLTV as 100% with a guarantee error (this is what shows on the approval)…OR do we report the TLV (total loan value) which on this would be 102.150.

Also, I could change the loan amount to $62,000 since that is the amount the borrower qualified for….BUT that amount does not show on the Note.

How do I report this???

Thanks,

[jholzknecht]

You should report the loan amount as the amount of the note. You report the LTV that you relied on.If you relied on 100%, then report 100%.

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