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#1524701 - 03/21/11 06:37 PM CD invesments qualify or not?
Trees Offline
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I know that if we have a CD loan and it was renewed we can still report it for the new CRA examination period even if the loan was originally granted years ago.

Can the same be said for investments? For example, we purchased a bond in 2008 with a maturity of 2012. So, we're still making payments on the bond. We reported it for 2008 CRA examination. Can we report it for 2009-2010 in view of the maturity date?

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#1524770 - 03/21/11 07:42 PM Re: CD invesments qualify or not? Trees
Khaleesi Offline
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That is how we treat our bonds. We count them up until maturity.
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#1524791 - 03/21/11 08:08 PM Re: CD invesments qualify or not? Khaleesi
Trees Offline
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OK. So your commitment may be 2007 but as long as you are still paying you can include the commitment amount. My predessor had two separate sections to his Investments info for the examiners. Those that were newly committed during the years being covered. So, for me, that will be new in 2009 and 2010. Then he had a separate section committed earlier but not matured yet. This would be bonds committed in, say, 2006 but not maturing until 2012. is this how you presented the info in your spreadsheet?

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#1524827 - 03/21/11 08:46 PM Re: CD invesments qualify or not? Trees
Khaleesi Offline
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Correct. For example I have a bond on my investment spreadsheet from 2005, it is still on our books until it matures in 2011. I will count the full commitment each year up to 2011 when it matures. I don't separate newly committed/committed-not matured.
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#1524902 - 03/21/11 11:09 PM Re: CD invesments qualify or not? Khaleesi
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I just list them with appropriate dates/amounts (and other descriptive information, of course). Which circles back to your other question on how much info to have - prospectuses, anything descriptive, etc.
Last edited by Kathleen B; 03/22/11 12:12 AM.
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#1524997 - 03/22/11 02:08 PM Re: CD invesments qualify or not? Kathleen O. Blanchard
Trees Offline
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Thanks. At least I will be on the right track with these, once I have the info.

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#1526308 - 03/24/11 01:54 PM Re: CD invesments qualify or not? Trees
Karen Tucker Offline
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Joined: Mar 2007
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Washington, DC
The agencies are supposed to treat originated and existing qualified investments the same in terms of evaluating their responsiveness and other qualitative factors. However, for the dollar amount, the examiners will need the current book balance for investments that were not originated in the current evaluation period, also any unfunded amount. In particular, see .23(e)-2 and .12(t)-8.

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#1526329 - 03/24/11 02:04 PM Re: CD invesments qualify or not? Karen Tucker
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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That is why it is good to have spreadsheets that show where it started, any movement of funds added to or removed (perhaps return of principal on some investments), and current balance.

Having a file on each investment where it is all tracked is the best way to go.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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