Q: When income and property value are factors in the credit decision, though not the dispositive factor, should such data points be reported?
A: Yes. When a credit decision is made, sections 1003.4(a)(10)(iii) and 1003.4(a)(28) require reporting of the data “relied on in making the credit decision.” Hence, if these data are relied on in making a credit decision, such data must be reported. There is no requirement in Regulation C for either of these data points to be the dispositive factor in order to be reported.
Specifically, comment 4(a)(10)(iii)-1 explains that when a financial institution evaluates income as part of a credit decision, it must report the gross annual income relied on in making the credit decision. For example, if an institution relies on the verified gross income of an applicant to make a credit decision, the institution is required to report the verified gross income. The comment does not state that verified gross annual income must be dispositive in the credit decision. Comment 4(a)(10)(iii)-1. Comment 4(a)(28)-1 provides a similar narrative for property value.
Income and property value apply the relied-on standard in a similar way to credit score, DTI, and CLTV and should therefore be reported if relied on in making a credit decision. See comments 1003.4(a)(10)(iii)-1, 4(a)(15)-1, 4(a)(23)-2, 4(a)(24)-1 and 4(a)(28)-1.
This Q&A was based on information contained in the Consumer Financial Protection Bureau’s HMDA FAQs Compliance Aid, which may be updated from time to time. This HMDA-related issuance may be found here: