[TheBank]

On purchased loans, the commentary states we can report age as NA 8888. Can we report NA for both the applicant and co-applicant fields for all of the purchased loans? or are we supposed to determine if there was a co-applicant and report 9999 instead of 8888 if there was no co-applicant?

Topic

[jholzknecht]

The commentary for paragraph 4(a)(10)(ii)(3) states, “a financial institution complies with § 1003.4(a)(10)(ii) by reporting that the requirement is not applicable when reporting a purchased loan for which the institution chooses not to report the age.” The 2019 Filing Instructions Guide indicates that the appropriate entry for “not applicable” is 8888, and the appropriate entry for no co-applicant is 9999. Based on Scenario 2 in the 2017 CFPB publication entitled HMDA Loan Scenarios (see page 13) the correct entry is 8888 for applicant, and 9999 for co-applicant.

[Author]

Replies