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#448160 - 10/27/05 04:10 PM SB & ISB exams - "Primary Product Line"
Anonymous
Unregistered

I recently heard reference to the examiner's use of the "Primary Product line" for analyzing loans during small and intermediate-small CRA exams. I looked through the exam procedures, but couldn't find a reference to specifically which loan products they look at. Has anyone had recent experience with this? What seems to be the determinant for just one "primary" (although there can be more than one). this will help immensely in self-assessment, and saved time in data integrity.

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#448161 - 10/28/05 05:51 PM Re: SB & ISB exams - "Primary Product Line"
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Bad news Chris...you don't get to sluff off on data integrity on the "less primary" product lines. They still examine those for data integrity as well and errors can cause the same level of trouble for you.

Primary product line is basically YOUR primary product line. In a small nutshell, are you a HMDA bank or a Small Business Bank? If you're a HMDA Bank, those numbers may weigh more heavily on your exam than the small business/small farm lending. If you're a small business bank, then the opposite is true.

When it comes to individual products within those categories, you may see lines like "Our opinion was based primarily on home purchase lending in the bank's market. Home improvement lending was not considered a factor given the very low number of these types of loans produced by the bank".

How do you know what you are? Well what do you do the most of Chris? I am a Small business bank, but do about a third of that level of business in HMDA lending as well. My exam is primarily rated based on the small business lending, but the HMDA lending is a factor in the rating. My exam specifically excludes my small farm lending and home improvement lending because I might see less than a dozen of those a year. How would your bank stack up?
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