From the 2012 Interagency CRA conference, it will take a great deal of negotiating, planning and programming but the current hope/plan is to combine this new reporting with CRA reporting so that we only have one business loan reporting process. There is no detail on that idea as there are many differences that will have to be worked out.

Thanks for the update.

We have been tracking this separately for years. The Department of Commerce funds a number of MBDAs around the country. I wouldn't wait for the federals to tell you how to do it. Change your systems now.....

You can collect all you want for other reasons but you won't know all that will be required or format etc for this particular purpose until the requirements are published.

Story from yesterday, no sense waiting for the regulators to tell us what to do....

http://finance.yahoo.com/news/l-mayor-office-recognizes-citi-190200194.html

Bridges to Business Success is a collaboration of Citi Community Development, the City of Los Angeles, the Los Angeles Housing Department, the University of Southern California Minority Business Development Agency, and the Southern California Minority Business Development Council. The program makes use of federal Neighborhood Stabilization Program (NSP) funds received by the City of Los Angeles to create jobs and revitalize neighborhoods. In the program, minority-owned, real estate-focused small businesses undertake an eight-week business training course at the University of Southern California and receive assistance in developing a strategic procurement plan.

I'm missing your point. Yes these programs exist but what we will be required to report are all applications from women and minority owned businesses with certain required fields etc reported similar to CRA and HMDA. I am not referencing participating in programs for CD credit.

And don't forget Kathleen, Make sure the data gathering is separate from the underwriting so there is no chance for discrimination. Not a direct quote but close enough. I think they forget that not all banks are large enough to have someone for each function in the bank.

Yes, it is that old don't look at the customer issue again.

Copy the Driver's License for CIP but don't DARE put it in the file! Mark the GMI page but don't EVER, EVER, EVER look at it again.

Perhaps we need to set up a confessional both for customers to meet with loan officers.

Forgive me father for I have borrowed....

Thanks Kaybee for the update. I've been waiting to hear more on the collection of these HMDA-like loan data since the announcement made by the CFPB last April (see below), but there hasn’t been any further development. I'm glad to hear that it was mentioned at the CRA conference. It’s nice to know that the data collection will be integrated with CRA reporting.

http://files.consumerfinance.gov/f/2011/04/GC-letter-re-1071.pdf