I seem to remember hearing or reading somewhere that loans to mortgage lenders, mortgage brokers and financial companies are not reported as small business loans. But I cannot remember where I heard it and I cannot find anything in the Guide to CRA Data Collecting and Reporting or Interagency Q&A.

Is this even the case, or did I hear some incorrect information somewhere?

If there is guidance out there, would anyone know where?

Would it matter whether our loan was for working capital or for re-lending ($1MM or less, of course)?

Thanks!

I know there is a separate category on the call report for loans to financial institutions but don't know if the ones metioned would be classified as such. I would read the call report instructions and see.

That's it, I found it in the Call Report Instructions. Thank you CRAatBOK!

You are welcome.

What you can do is point out this lending in your performance context, detailing how many mortgages (or total $) in your area were funded due to financing from your bank.

Get some info on the loans funded (maybe pull their HMDA?) and talked sbout how much low/mod etc.

I would not leave it unmentioned.

Unless it is preditory.

Right. That would be bad. But i see many that are not. It would be foolsh to leave it out of the banks performance data. If the bank is funding predatory loans via a broker or lender they need to address that issue.

I am aware of a bank that received a needs to improve because the investment area, unrelated to CRA investments, purchased a portfolio of subprime mortgages for the return. It negated all of the good work the bank had done.

I used to cringe when I saw the bank I worked for make loans to Check Cashers and other types of preditory lenders. They just saw it as a great cash business. Grrrr.

Not all non-bank mortgage lenders make predatory loans. I see ones that are the normal stuff you see in a bank.

True, but the bank should know for sure before making the loan.

Yes they should but that is a whole other discussion.