Under CRA codes, where is the money to be used? Do we report the location of the collateral or borrowers address?

-From Reg BB definitions:

o) Loan location. A loan is located as follows:
(1) A consumer loan is located in the geography where the borrower resides;
(2) A home mortgage loan is located in the geography where the property to which the loan relates is located; and
(3) A small business or small farm loan is located in the geography where the main business facility or farm is located or where the loan proceeds otherwise will be applied, as indicated by the borrower.

If you need more guidance on commercial loans, do a search on "location" in this forum, and look at the CRA Q&As.

The "borrowers address" is a bit of a vague term. The "borrower" might like his business mail sent to his home, a po box, or his girlfriends house, none of which are likely to be the business operations address. Be sure you have that clear in your mind when training staff. (We do not allow the mailing address to filter to the CRA geocoding system here).

You can use (as noted above) the address of the business operations, or the address wehre the proceeds were applied. You HAVE to develop a system for one or the other though, and not pick and choose. The last thing you want to do is look like you're picking the address you use based on the type of tract it's in, to artificially inflate your CRA lending in LMI tracts.

Oh....just put the map up on the wall and throw a dart!

Except of course on the first Thursday following the first Tuesday of the month after a full moon in a month ending in "Y."