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CRA
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We're exploring current CRA data reporting requirements for large banks. Every source I found including the FFIEC's Guide to CRA Data Collection cites the requirement to report small business / farm gross annual revenue of $1 million or less. But the Reg states the following:
(vii) An indicator for whether the loan was to a business or farm with gross annual revenues of $250,000 or less;
(viii) An indicator for whether the loan was to a business or farm with gross annual revenues greater than $250,000 but less than or equal to $1 million;
(ix) An indicator for whether the loan was to a business or farm with gross annual revenues greater than $1 million; and
(x) An indicator for whether the loan was to a business or farm for which gross annual revenues are not known by the bank.
So will we need to report simply $1 million or less, or are there 3 reporting tiers starting at $250,000? Can somebody help clear up my confusion?
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Lending Compliance
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I caution against using specific lender credits here because the fees in question are finance charges. Depending on your system, reducing the borrower cost of a finance charge and transferring the reduction to the Paid by Others column (specific lender credits) may mess with the finance charge, total of payments, and APR on the closing disclosure. Instead, show the points paid in the borrower and seller columns and make your lender credit for overcharges in the general lender credit in Section J and in the CD page 1 Closing Costs line.
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Chat! - BOL Watercooler
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Love Gun - Kiss
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Chat! - BOL Watercooler
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(You Gotta) Fight For Your Right (To Party) - Beastie Boys
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Chat! - BOL Watercooler
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I Love - Tom T. Hall
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Need to Remain Anonymous
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Thank you so much for your feedback!
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BSA/AML/CIP/OFAC Forum
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Thank you for the information. I think it's time to seek legal counsel.
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Chat! - BOL Watercooler
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I Like Beer--Tom T. Hall
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Chat! - BOL Watercooler
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Can't Fight This Feeling - REO Speedwagon
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Chat! - BOL Watercooler
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That's The Way (I Like It) - KC & The Sunshine Band
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Lending Compliance
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A little late to the conversation but if the title has been retired then your DOT/mortgage will encompass the MH.
You questioned the ROR but now with the title being retired other regulatory requirements kick in....flood, HMDA, Reg. B appraisal rules, etc.
You will want to expand your review to cover those topics too if you haven't' already.
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BSA/AML/CIP/OFAC Forum
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Adverse media screening isn't required, but if you end up doing business with someone who does have adverse media out there, and they end up committing financial crime through your FI, the regulators can force you to do it moving forward.
If set up correctly, adverse media screening is a powerful tool to help detect prevent financial crime. However, it needs to be appropriate to your FI's risk profile.
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BSA/AML/CIP/OFAC Forum
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A corporation does not die. The shareholder may have died, but the corporation lives on. Whether the authorized signer can close the account under any circumstances would be governed under the corporate resolution that you received when the person was appointed as the corporate signer outlining their powers as it relates to the account. If you have questions, have your legal counsel review the account documentation.
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BSA/AML/CIP/OFAC Forum
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Owner of corporate account is deceased. Can the authorized signer close the account? What docs do we need?
Example: XYZ Corp. dba ABC Market
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Chat! - BOL Watercooler
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Congratulations, Susielou!
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Operations Compliance
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You mean an example of some bank using it?
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Need to Remain Anonymous
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When you say this is for a commercial purpose, I assume you deemed this an agricultural related loan. It would not be HMDA reportable.
Official Interpretation
Paragraph 3(c)(9)
1. Loan or line of credit used primarily for agricultural purposes. Section 1003.3(c)(9) provides that an institution does not report a closed-end mortgage loan or an open-end line of credit used primarily for agricultural purposes. A loan or line of credit is used primarily for agricultural purposes if its funds will be used primarily for agricultural purposes, or if the loan or line of credit is secured by a dwelling that is located on real property that is used primarily for agricultural purposes (e.g., a farm).
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Chat! - BOL Watercooler
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The Way - Arianna Grande and Mac Miller
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Chat! - BOL Watercooler
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Can't Fight The Moonlight - LeAnn Rimes
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Need to Remain Anonymous
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I would report this as a small farm loan, assuming the amount at origination was $500,000 or less.
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Lending Compliance
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The bank's general lender credit would be only for the increased borrower costs. Your loan estimate is only given to the borrower/applicant.
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Deposits and Payments
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Can anyone walk me through how to use the maturity calculator in Navigator? I am at a new bank, haven't used Navigator in seven years and no one here knew anything about the calculator option. I tried to muddle through it but at the bottom of the maturity tab in change mode, the forfeiture override drop down gives multiple options with no context and I'm unsure how to proceed (or maybe I'm in the completely wrong place?). We have a dormant CD (both owners deceased for two years) that we need to payout tomorrow and need to remove the forfeiture fee. Any help would be greatly appreciated!
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Need to Remain Anonymous
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Need your expertise please. We have a commercial loan that is for the purchase of 67 acres farm & pasture land, which is the predominant use of the property. There is also a home on the property.
I know that vacant land would not typically be reportable for small business, but would I report it as a small farm loan due to the agricultural use? Or do I need to report for HMDA because there is a residence on the property?
Any advice is appreciated!
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Chat! - BOL Watercooler
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