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#264698 - 10/29/04 03:09 PM
CRA Loan Type
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Diamond Poster
Joined: Sep 2002
Posts: 1,117
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I have looked at the CRA Loan Info Sheet available in the tools section and I have a couple of questions. In the section indicating CRA type... 1) Can a CRA type loan classified as "other business loan", be secured by residential real estate? 2) Can a CRA type loan classified as "business loan" be an auto or truck loan to a business or individual for business purpose? I cannot find either of these as options in my preparations to report as a large bank. 
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Michelle CRCM
"What would you attempt to do if you knew you could not fail?" ~ unknown
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#264699 - 10/29/04 04:21 PM
Re: CRA Loan Type
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Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
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A CRA Loan Type code 3 "Lines or loans for Other Business Purpose can be collateralized by residential property. You should code these as a 3 and ask examiners to consider them for additional CRA credit. When a loan officer has the "Abundance of Caution" syndrom and takes an SFR as collateral, on an otherwise Small Business loan, this is how you would code them.
Can Small Business loans be autos or trucks IMO yes. Just because it is a consumer loan doesn't mean it can't be a Small Business/Farm loan.
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Compliance Analysis and Research - Software for your CRA/HMDA analysis needs
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#264700 - 10/29/04 06:20 PM
Re: CRA Loan Type
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Diamond Poster
Joined: Sep 2002
Posts: 1,117
On the road...
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This is what I have on my input sheet for CRA type (I am trying to tie it to our internal purpose codes to make things easier)
01- Business Loan – Loan amount is $1 million or less. Include Loans and Lines of Credit, Equipment, Dealer Floor Plans, and loans to finance construction that are not secured by real estate. Not secured by real estate. Purpose Code 510
01 Other Business Loan – Loan amount is $1million or less. Loan secured by real estate or other liens on business and industrial properties, churches, educational/charitable institutions, clubs/lodges, “homes” for aged persons, golf courses, hospitals, dormitories, recreational facilities, and similar properties. Purpose Code 170
02 Farm Loan – Loan amount is $500,000 or less. Collateral is farmland and improvements thereon. Farmland includes all land known to be used or usable for agricultural purposes, such as crop and livestock production. Farmland includes grazing or pasture land, whether tillable or not and whether wooded or not. Purpose Code 120
02 Other Farm Loan – Loan amount is $500,000 or less. Loan to finance agricultural production and other loans to farmers. Includes loans made for the purpose of financing agricultural production, loans to farmers for purchases of farm machinery, equipment, and implements, and loans to farmers for all other purposes associated with the maintenance or operations of the farm, including purchasing of private passenger automobiles and other retail consumer goods and provisions for the living expenses of farmers or ranchers and their families. Not secured by real estate. Purpose Code 410
03 Other Lines/Loans for Small Business Purposes – Loans made to small businesses secured by residential real estate.
Community Development –
(1) Business loans over $1 million that have a community development benefit, or
(2) HMDA reported loans that have a community development benefit, or
(3) Business loans secured by residential property – purpose has a community development benefit,or
(4) Construction loans with a community development benefit
Other Loans Not Elsewhere Classified - Business purpose loans and Construction loans over $1 million. Also report Letters of Credit and construction loans under $1 million that are NOT community Development.
Am I on the right track?
Last edited by Joey's Mom; 10/29/04 06:35 PM.
_________________________
Michelle CRCM
"What would you attempt to do if you knew you could not fail?" ~ unknown
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#264702 - 10/29/04 07:05 PM
Re: CRA Loan Type
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Anonymous
Unregistered
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I'm new to this CRA reporting - and I see you have referenced designated 'type' codes for CRA. Where can I find these desingated codes and a definition? Thanks!!
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#264703 - 10/29/04 07:13 PM
Re: CRA Loan Type
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Diamond Poster
Joined: Sep 2002
Posts: 1,117
On the road...
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I am still very new to large bank and obviously still figuring things out.  But start with FFIEC's A Guide to CRA Data Collection and Reporing I also downloaded the data entry software from the ffiec and started reading anything and everything. Good luck! 
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Michelle CRCM
"What would you attempt to do if you knew you could not fail?" ~ unknown
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#264705 - 11/01/04 05:35 PM
Re: CRA Loan Type
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Anonymous
Unregistered
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I'm reading the reg and the Q&A...but I can't find any reference to the actual 'type codes' and their definition. Is this stuff only in the filing software? Thanks for any clarification!
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#264706 - 11/01/04 06:11 PM
Re: CRA Loan Type
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Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
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You can find all the codes used for reporting in the HELP file of the software.
CRA Loan Type
1=Small Business
2=Small Farm
3=Other lines and loans for purpose of small business
4=Home Equity
5=Auto
6=Credit Card
7=Other secured consumer loans
8=Other unsecured consumer loans
9=Other Loan Data
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Compliance Analysis and Research - Software for your CRA/HMDA analysis needs
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#264707 - 11/01/04 06:25 PM
Re: CRA Loan Type
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Power Poster
Joined: Apr 2004
Posts: 8,990
Cincinnati, OH
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Quote:
You can find all the codes used for reporting in the HELP file of the software.
CRA Loan Type
1=Small Business
2=Small Farm
3=Other lines and loans for purpose of small business
4=Home Equity
5=Auto
6=Credit Card
7=Other secured consumer loans
8=Other unsecured consumer loans
9=Other Loan Data
While you can collect all of the above types of data, the only ones that are reported are types 01 and 02.
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#264709 - 11/01/04 06:50 PM
Re: CRA Loan Type
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Power Poster
Joined: Apr 2004
Posts: 8,990
Cincinnati, OH
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Quote:
Quote:
Quote:
You can find all the codes used for reporting in the HELP file of the software.
CRA Loan Type
1=Small Business
2=Small Farm
3=Other lines and loans for purpose of small business
4=Home Equity
5=Auto
6=Credit Card
7=Other secured consumer loans
8=Other unsecured consumer loans
9=Other Loan Data
While you can collect all of the above types of data, the only ones that are reported are types 01 and 02.
To be totally accurate, you must report types 01 and 02. You may report the others, at your option. If your institution does little or no business lending, you'll want to strongly consider reporting your other loan types.
Exports sent to the regulators only include types 01 and 02. You may collect the others, but they are not transmitted.
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#264710 - 11/01/04 08:26 PM
Re: CRA Loan Type
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Anonymous
Unregistered
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Thank you all, I was going blind trying to find it in the regulation - you'd think they might consider following HMDA format, when providing codes/definitions - but oh well. Thanks again!
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#264712 - 11/03/04 02:35 PM
Re: CRA Loan Type
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Power Poster
Joined: Apr 2004
Posts: 8,990
Cincinnati, OH
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Quote:
Quote:
Exports sent to the regulators only include types 01 and 02. You may collect the others, but they are not transmitted.
You are splitting hairs. If you might want other loans considered, and many do, the loans need to be coded up front and logged and checked or it would be a nightmare.
Andy, I am not splitting hairs, I am clarifying. I have worked with several banks that were unclear on this, so I felt explaining my earlier comment was important.
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#264713 - 11/03/04 05:23 PM
Re: CRA Loan Type
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10K Club
Joined: Oct 2000
Posts: 27,752
On the Net
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Sorry. I just didn't want it to sound as though there was no need to collect this data and log it. The bank has to go into this knowing if it wants that data, before the exam starts.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#264714 - 11/03/04 05:35 PM
Re: CRA Loan Type
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Power Poster
Joined: Apr 2004
Posts: 8,990
Cincinnati, OH
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Quote:
Sorry. I just didn't want it to sound as though there was no need to collect this data and log it. The bank has to go into this knowing if it wants that data, before the exam starts.
Absolutely! I totally agree. If they are going to collect this data, they need to start in January and keep up with it all year long unless they make very few very large loans!
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#264715 - 11/07/05 06:17 PM
Re: CRA Loan Type
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Anonymous
Unregistered
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Quote:
Quote:
Can Small Business loans be autos or trucks IMO yes. Just because it is a consumer loan doesn't mean it can't be a Small Business/Farm loan.
Since these are not reported on the call report do we use CRA type code 05?
You may have to recode these loans and change your call report. We did. We were told that if the auto or truck loan was to a business (usually titled in the business name) then it is a business loan and should be call reported and reported for CRA as such.
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