Reg O - Directors (not Executive officers). Are primary residences subject to Reg O reporting for directors? Are there specifics to when they are or not be be reported such as on the mortgage system, loan side, 2nd lien or purpose like Executive officers?
Under CRA, what constitutes a commercial or Industrial purpose? I have looked for a definition to no avail. Would this include a loan to a small business for a capital injection?
Where on the call report will I find the RSSD ID Number?
I need the legal definition of owner occupied. I processed a loan recently for a business and our collateral was vacant land. I was told this would be considered owner occupied because the borrower owns the property. After 15 years as a loan processor, I have NEVER heard it explained this way before. I was told owner occupied is not related to whether the owner lives there, or not.
Is CRA purpose driven or collateral driven?
We have loans secured by multiple duplexes, 3 or more, that are reported with a call report code of 1D (5+ Family). Is this correct.
We are trying to clarify an item from the Official Staff Commentary of Reg C - 2(g) Home Improvement loan. The commentary indicates “Classification requirement for loans not secured by a lien on a dwelling. An institution has “classified” a loan that is not secured by a lien on a dwelling as a home improvement loan if it has entered the loan on its books as a home improvement loan, or otherwise coded or identified the loan as a home improvement loan.” We have not reported any loans to our Call Report as home improvement nor are any identified as home improvement in our underwriting summaries or on our core system. However, in review of loan notes, the purpose is stated to be for a "new roof", but not specifically home improvement and it’s not "classified" as stated above as home improvement. The loan is for a condominium complex with assessments as collateral. Should this loan be included on the HMDA LAR as home improvement?
Are we required by the FDIC to show our letters of credit on our balance sheet? We carry ours as a participation, but because it is unbooked, it doesn't show on our balance sheet. At all of the other FDIC banks I've worked for, we've been required to show our letters of credit on our balance sheet.
Under Reg O, do I report the total outstanding loan on the call report, or the amount that the insider is limited to through his guaranty? For example: Mr. S has a loan for $500,000, but only guarantees 10% of that loan. Should $500,000 or $50,000 be reported on the call report?
We are reviewing our collateral and purpose codes. Are the codes standardized in the industry or are we free to create our own? Do they flow to the call report?