Interagency Q&A .42(c)(1)(iv) – 4: Whose income does an institution collect when a consumer loan is made to more than one borrower?

Compliance > Regulation BB - CRA
Q:  § __.42(c)(1)(iv) – 4: Whose income does an institution collect when a consumer loan is made to more than one borrower?
 
A:  An institution that chooses to collect and maintain information on consumer loans collects the gross annual income of all primary obligors for consumer loans, to the extent that the institution considered the income of the obligors when making the decision to extend credit.  Primary obligors include co-applicants and co-borrowers, including co-signers.  An institution does not, however, collect the income of guarantors on consumer loans, because guarantors are only secondarily liable for the debt.
 
 
 
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
 
 

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