Q: § __.42(c)(1)(iv) – 1: If an institution does not consider income when making an underwriting decision in connection with a consumer loan, must it collect income information?
A: No. Further, if the institution routinely collects, but does not verify, a borrower’s income when making a credit decision, it need not verify the income for purposes of data maintenance.
This Interagency Q&A, and others, was released in July 2016.
The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately. They may be found here: http://www.ffiec.gov/cra/qnadoc.htm