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#119222 - 10/01/03 06:42 PM CRA - Renewed loan credit
Ninky Offline
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Ninky
Joined: Nov 2002
Posts: 357
I am new to CRA data reporting. The reporting guidelines address renewals with new money, but I cannot find an answer for this: Loan in 2002 for $100,000. Renews in 2003 for the amortized balance of only $30,000. How does this get reported for CRA 2003, or does it? And can you direct me to commentary or guidelines addressing this? Any help would be most appreciated.

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Lending Compliance
#119223 - 10/01/03 08:14 PM Re: CRA - Renewed loan credit
Anonymous
Unregistered

The loan would be reported in 2002 for $100,000 and it would be reported in 2003 for $30,000. If it is a revolving line of credit you would report the entire amount of the line. There is guidance on this in the CRA Q&As at the back of the Reg.

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#119224 - 10/01/03 09:08 PM Re: CRA - Renewed loan credit
HRH Dawnie Offline
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HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
http://www.ffiec.gov/cra/guide.htm

I find the reg rather tedious to read on occasion (Shhh don't tell)

This guide is a quick and handy source for the type of question which was just posted. It's not only handy for the folks who report (ie the CRA Officer) but also for staff. The book specifically deals with LR Reporting, verses forcing them to wade through the regulation.

If you wander through these links you'll find the same guide for HMDA currently, and the new rules for next year. Again, great reference materials.
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#119225 - 11/17/03 10:35 PM Re: CRA - Renewed loan credit
Lestie G Offline

Power Poster
Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
I'm going to revive this thread with another question.

Which of these are reportable (if any):

1. Large master note for purpose of buying cattle - no draws are made against this note on our system.
2. Many small notes under the master note for the purpose of purchasing individual pens of cattle - draws are made on these.

Each small note has a unique loan number and is booked as a separate note on our loan system. Should we consider the many small notes as simply draws on the master, and only report the master - or should we not report the master and only report the many small notes?
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Opinions my own.

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#119226 - 11/18/03 07:59 PM Re: CRA - Renewed loan credit
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
A couple of issues raise when I read this.

First this is a farm loan...remember size matters is this deal over $500M? (The master note). If so...it's not reportable, if it's below $500M then keep reading...ahh heck Lestlie, keep reading anyhoo!

I have a similar deal that on my books. The master line is well above reporting limits, but system requirements force us to book ooddleesss of small loans for each draw due to the type of business and collateral. My regulators advice was, don't report the master note but report each of the individual notes because they show on the system. Leaving these deals out of our reporting could cause issues with data integrity (lots of seemingly reportable deals not making the LR). BUT! (Big But) this is ONLY done due to the system issue. You wouldn't want to do this to artificially inflate your CRA numbers. And, if you do it for one, do it for all that you have on the books operating under the same type of scenario. Consistancy ya know

If the master line is below $500M (small farm) or $1MM (small business) then I was told to report this as well, if there is a formal note signed meeting all the general requirements of a small business loan. If it's a more informal issue (say the bank has decided through a credit memo that this client can borrow up to XXX amount of bucks without board approval, but the client is unaware of this, and a note is not signed) then it's not reportable of course as you can't tie it to a real note.

And...(that's my 50th and isn't it?) if it's a CD deal...don't try to double dip and take the small deals and the large deal You'll get beat with a wet noodle or a chopstick by any decent examiner out there.
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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