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Can the bank use "NA" in the income field on the HMDA LAR? May the bank also report "NA" for the debt-to-income ratio?

It is the bank's understanding that, to protect an employee's privacy, the bank can use "NA" in the income field on the HMDA LAR. May the bank also report "NA" for the debt-to-income ratio for the same reason and so that others cannot "reverse engineer" the math to determine the income?

No. When it comes to employee privacy, only employee income may be reported as "NA." (May 2018)

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