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For HMDA reporting purposes, if a borrower has an income of $98,499.12, should we round that down to $98,000 or up to $99,000? – IBA Compliance Connection

IBA Compliance Connection

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For HMDA reporting purposes, if a borrower has an income of $98,499.12, should we round that down to $98,000 or up to $99,000?

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The Home Mortgage Disclosure Act and Regulation C require banks to round income to the nearest $1,000 (with $500 rounding up to the next $1,000). In this case, $98,499.12 rounds down to $98,000.00 and would be reported in thousands as “$98”.

For resources related to our guidance, please see:

  • Regulation C, 12 CFR 1003, Appendix A, Paragraph D6 (“Income. Enter the gross annual income that your institution relied on in making the credit decision. a. Round all dollar amounts to the nearest thousand (round $500 up to the next $1,000), and show in thousands. For example, report $35,500 as 36.”)