What documentation would you suggest to prove a community development loan with the purpose of revitalization/stabilization in a moderate- income area? We are financing the purchase and construction of a mixed use development with upper income housing, retail and commercial space. The housing units have been completed but our loan will finance the finish out of the retail/commercial space. Development has TIF credits that our borrower will receive.
I'm new at CRA and while I'm sure a construction loan isn't HMDA reportable and wouldn't be CRA reportable as Small Business (collateral is residential property). Is it possible a construction loan could be CRA reportable as Other Business Loan? My borrower is building homes for business purpose, secured by the residential property being built.
Is CRA purpose driven or collateral driven?
In order to receive the CRA services credit, does the bank employee have to be a direct representative of the bank? Would it count if an employee is volunteering with tax preparation assistance through a non-profit organization?
What is required in a large bank CRA public file?
I have a question that involves CRA Reporting for community development loans. If we have mortgage loans that are made to LMI borrowers or are in LMI areas, can we include these as community development loans on our CRA report? They are also included on our HMDA report. I know we get credit for these, but my question is whether we should include them on the CRA report to the FDIC as community development loans.
The agencies have proposed new and revised CRA questions and answers designed to elaborate on and clarify the changes to CRA that took effect on September 1, 2005.
E. Matthew Quigley is the OCC's new Director of Community Development.
Have you ever gone back and looked at a law or regulation when it was just adopted and then compared it to today's version? Take CRA for example.
The three banking agencies, OCC, FDIC and the FRB, have issued final revisions to the CRA regulation. The changes take effect on September 1, 2005.