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#138155 - 12/10/03 05:22 PM
Re: CRA Reportable?
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10K Club
Joined: Aug 2002
Posts: 34,318
under the Lone Star
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More info needed:
Is the loan amount less than $1 million, or are the annual revenues of the borrower less than $1 million ? A third question would be: are you reporting this under HMDA as well ? Multifamily lending is the only type that can get us double credit.
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#138157 - 12/10/03 05:53 PM
Re: CRA Reportable?
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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If it's a multi-family dwelling you can. Looks like you're in luck.
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#138161 - 12/11/03 12:37 AM
Re: CRA Reportable?
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Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
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HMDA reportable except on alternate Tuesdays following the first Monday of a month that follows a month ending in "Y".
The above exception does not apply if the following Thursday occurs during the first quarter phase of the Moon. In those cases, the test to determine if reporting applies should be conducted along a North-South axis while facing in a south easterly direction. If the number of units is more than 4 and is an even number, then reportability will be positive if the borrower's shadow falls on the east of a line drawn along the North-South axis.
If the number of units is more than 4 and an odd number, then the reportability will be positive if the borrower's shadow falls on the west of a line drawn along the North-South axis.
If the number of units is less than 4, then reportability will be positive if a coin with a value greater than one-tenth of one dollar is projected vertically and lands with the face value against the ground.
Bwah-hah-hah!!!!
I'm considering my application to run HUD!!!
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CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
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#138162 - 12/11/03 03:32 AM
Re: CRA Reportable?
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10K Club
Joined: Aug 2002
Posts: 34,318
under the Lone Star
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Bonnie: You are bad, very bad. I wonder why we haven't heard from the original poster in a while. He or she must think we are nuts, when in actuality, it is the HMDA/CRA regs that are nuts.
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Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.
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#138164 - 12/11/03 12:18 PM
Re: CRA Reportable?
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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Bonnie - I love your rules. I actually wish I had them last week when I did my HMDA training. That would have been a great ice breaker.
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#138166 - 12/11/03 07:32 PM
Re: CRA Reportable?
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Anonymous
Unregistered
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Hi you guys, it's me the original poster. I've sort of just been waiting to see what all different answers I get. Apparently, I'm going with it's not HMDA or CRA reportable, as it is construction financing. Still a little fuzzy though.
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#138167 - 12/11/03 10:45 PM
Re: CRA Reportable?
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100 Club
Joined: Sep 2001
Posts: 206
Myrtle Beach, SC
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Thanks Bonnie! I'm going to use this next week in a HMDA training class to break the ice, unless of course, you have it copyrighted?! Makes as much sense as the rules!
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#138169 - 12/11/03 10:54 PM
Re: CRA Reportable?
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Platinum Poster
Joined: Mar 2002
Posts: 721
California
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Whatdoyoumean? Is the loan to a contractor or a business? Is the loan over $1 Million?
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#138171 - 12/11/03 11:12 PM
Re: CRA Reportable?
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Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
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Quote:
Hi you guys, it's me the original poster. I've sort of just been waiting to see what all different answers I get. Apparently, I'm going with it's not HMDA or CRA reportable, as it is construction financing. Still a little fuzzy though.
Generally speaking, ground-up construction financing is not reportable on either HMDA or CRA. If the construction prjoect does not contain affordable housing for low- mod-income individuals, then you cannot get Community Develoment credit either.
For all intents and purposes, it becomes a non-event in the CRA/HMDA world.
HOWEVER - if you have a loan on an EXISTING dwelling to construct repairs or improvements, then it WOULD be HMDA reportable.
And if the dwelling is for low- mod-income housing, then you would also report it as part of your aggregate number/dollars of Community Development loans.
Just make sure you don't step on any cracks on your way to work that morning....
_________________________
CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
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#138173 - 12/12/03 08:47 PM
Re: CRA Reportable?
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Anonymous
Unregistered
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So, what if a builder is purchasing land to build houses and places the land as collateral? In this case, it wouldn't be HMDA or CRA reportable?
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#138175 - 12/23/03 04:27 PM
Re: CRA Reportable?
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Anonymous
Unregistered
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I also have a "Is it reportable?" question which I hope isn't a stupid question. If the loan is a small business loan as defined, but the collateral is a blanket lien on A/R and equipment, should this be reported on the CRA register? Other than residential real estate, does collateral matter? (Oops, that's 2 questions) Thank you so much.
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#138176 - 12/23/03 08:05 PM
Re: CRA Reportable?
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Junior Member
Joined: Sep 2003
Posts: 43
West Coast
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Yes, the loan secured by blanket A/R is reportable if it is under one million.
Business purposes loans secured by residential real estate and construction loans are excluded from the definition of small business loan. Bonnie is correct -- you really have to study and understand the call report definitions to get this right.
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#138177 - 12/24/03 12:06 AM
Re: CRA Reportable?
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Power Poster
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
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Wow I missed a doozy of a question here I am so glad though that I got Bonnie's rules! It all makes sense now!!! You rock girl. To the last question, both the borrower type and the purpose of the loan are as important as size in determining if a loan is CRA reportable. As Bonnie mentioned, there are a whole slew of loans that are size wise, seemingly CRA reportable, but when purpose and borrower come into play, they get tossed out of the mix and become eligible for only community development (if any) credit. http://www.ffiec.gov/cra/pdf/cra_guide.pdfThe Call Report instructions are the defining factor, but this publication (check out page 46 on after you read 1-45) discusses when and why a loan is NOT reportable. And now for 32 seconds of my favorite CRA training program: Attention: REVENUE SIZE IS NOT A FACTOR IN DETERMINING IF A LOAN IS CRA REPORTABLE (cuz whenever I discuss reportable goober someone asks that question!)
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Dawn Coursey VP/CRA Queen
CRA Rating is in...Oh who cares...I'm home with the baby.
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