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#1505133 - 02/04/11 02:54 PM ISB CDL Questoin
whoop Offline
New Poster
Joined: Feb 2011
Posts: 2
Texas
We are at the point where we are ISB. Have been studying this to get prepared. We are a small bank in a rural area that does mostly loans to small farms and small business with gross revenues under 1 million. I assume these will qualify as Community Development loans with what I have read under the regs.
We have also purchased munis for many school districts and such. How do I documen these to qualify for QI if possible

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CRA
#1505375 - 02/04/11 04:58 PM Re: ISB CDL Questoin whoop
whoop Offline
New Poster
Joined: Feb 2011
Posts: 2
Texas
Sorry about poor grammar. Was in a rush and headed to a meeting. As far as the farm and small business loans go, how is it reccomended that we document these? I guess I should also ask if they qualify? By my reading I assume they do but I would be lying if i said I wasnt deeply confused reading all the information.

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#1505786 - 02/05/11 02:35 AM Re: ISB CDL Questoin whoop
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,089
Connecticut
Not all small farm and small business loans qualify for Community Development recognition. They must meet the "economic development" definition which means job creation, preservation or improvement primarily for LMI persons.

We always recommend that an ISB collect and report their CRA loan data on a voluntary basis. If you are going to take your CRA responsibilities seriously you must be collecting the data and monitoring it. So why not report it? - especially if it preserves your elective to be examined under the Large Bank standards.
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