A question has come up in regard to public comments left on the bank's Facebook page. Would Facebook comments that relate to the bank's performance in helping meet community credit needs rise to the level of placing these in the bank's Public File?
I am trying to obtain a good definition and/or guidance on how to report Revolving Lines of Credit that have been extended and not renewed for a particular year. Example – A customer has a revolving line of credit for $250,000 that originally was executed in November 2014 and is up for renewal in November 2015, however the borrower has asked for a 3-month extension which the bank granted, the amount and conditions are unchanged.
For 2015 reporting, can we/should we be reporting/treating the $250,000 as a renewal/extension that took place in 2015? Or not report it as it was an extension and not a renewal according to the CRA quidelines?
What type of rating system does a regulatory agency use to assign a CRA rating?
Can the bank adjust an assessment area once it has been set?
The CRA regulation states, "generally, an institution is to rely on the revenues that it considered in making its credit decision." It also states, "The regulation does not require institutions to request or consider revenue information when making a loan; however, if institutions do gather this information from their borrowers, the agencies expect them to collect and rely upon the borrowers' gross revenue for purposes of CRA."
Does one of these trump the other? We use personal income for the credit decision and rarely use gross revenues of the business. Our auditors think the "credit decision" amounts outweigh using what we have in the file. If we only used the credit decision amounts, we wouldn't have many loans to report.
We are ordering new mandatory signage for the bank lobby. Our CRA notice and the annual disclosure notice that has always been posted in the lobby has been a printout. I have been looking on line and the pre-printed notices have a "clear pouch." What is suppose to be put in the clear pouch?
What's the difference between a REMA and an Assessment Area?
With regard to reporting non-dwelling secured or unsecured business loans for CRA credit, what are the characteristics of a modification versus a renewal?
I was given a figure by our strategic planning team that one of the bank's strategic goals over the next three years is to achieve 80% employee participation in yearly CRA service. I was not asked for input on this goal, it was just handed to me. This number seems exorbitantly high, in my opinion. We're about 1000 employees, so this means that over three years, we would have 800 instances of volunteerism.
My question is, what documentation or best practice exists on an acceptable percentage of employee participation in service activities? I'm having trouble finding this information anywhere, and I need something to back up my assertion that this number is way high and will be difficult to achieve.
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?