The CRA loan location is where the business or farm office is...correct?! So, if you had nonfarm,nonresidential collateral on the loan you would not use that address for geocoding...correct?! I am looking at a loan for a customer that has multiple convenience stores and they operate them out of either an office or their home. So, this loan is on their newest store and that property's mortgage is the primary collateral. Or the same scenario could be a farmer that has purchased additional acreage away from the homestead...

You should report the businesses corporate address. If the corporation is located in their home, then that is the address you use. Don't use the local office address or a store address.

Actually both addresses are acceptable. Either the location where the proceeds were used or the business headquarters are acceptable. So in the case of the convenience stores, you could use each store address, or the corporate offices.

When using a home address, be really sure that they're running the business out of their home, and not just using it for mail purposes (ie a business credit card for a doctor going to his home address, but he has a clinic, the clinic would be the address to use). But, there are occasionaly going to be businesses where the owners home address is legit, such as contractors, perhaps this store scenario, etc.

When chosing which address to report, it's important to be consistent. You don't want to geocode two options and use the one most advantage to your CRA standing (ie a low or mod tract over a high or middle one). We use collaterall location predominately, but occasionaly use corporate address when the collateral will be out of state.

Our method is consistent and acceptable because our geocoder program has purchased data for our state, and using the in state address allows for batch coding.

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You should report the businesses corporate address. If the corporation is located in their home, then that is the address you use. Don't use the local office address or a store address.

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I disagree. CRA wants you to follow the money. If the money is being used for a store in a certain location, then that is what you really should report. Your CRA register should accurately portray where money was made available for commerce.

Think of this - the owner's "corporate" address is his home in an upper income area, but he or she opens stores located in Enterprise Zones, or other low- and moderate-income areas, thereby providing employement opportunities for residents in those areas.

It doesn't make sense to say you're lending to a business in an upper income area when in fact your bank's money went into an area that really needs it.

We also follow the money and our CRA examiner stated that this was the preferred practice at our last exam. In cases where we do a loan that benefits several of his locations, we use the corporate address. For example, if the loan is for updating one store, we geo to that store; if the loan is working capital for all the stores, we geo the corp. office. The main thing here is to be consistant in how you determine what to geo.

We actually were told the opposite by our examiner. Consistent, yes. But they indicaed to always use the address of the "corporate office" vs. loan location. We disagree, but what do you do?

I prefer to show where the money is going, particularly if it will be used to improve a low or moderate-income neighborhood, and I recommended that to bankers in my examining days. It makes more sense to show what neighborhoods are benefitting from loans being made to build or open businesses, rather than just showing the dollars going to the corporate headquarters every time.

Q & A 228.42(a)(3) also provides guidance in this regard if the proceeds are used in a variety of locations.

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We actually were told the opposite by our examiner. Consistent, yes. But they indicaed to always use the address of the "corporate office" vs. loan location. We disagree, but what do you do?

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Anon, you go to your regulators omnibudsmen and discuss the issue if you can't get your regulator to understand the issue. Geocoding to the corporate office 100% of the time would not paint a picture of the benefits of loans your bank provides in it's AA for all the reasons we've pointed out.

Both addresses are acceptable. I too follow the collateral (use of funds typically) for a multitude of reasons, but the main one being that it shows where the benefit of the proceeds were used. Also, it keeps my loans pretty much in Alaska, where I'm set up for batch geocoding. Using corporate offices means everytime I do a credit card for a large oil company, I would book it to Texas, despite the fact that these companies tend to handle these types of debt structures in the state where the card is being used.

I guess I'd spend the amount of time and effort on this that was necessary. If you do a lot of deals with large corporations outside of your AA, I'd spend time working through it with your examiner. If you do very very few, it's probably not worth bothering with.