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#1700937 - 05/18/12 11:43 AM Renewals
DCollins Offline
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DCollins
Joined: Oct 2001
Posts: 707
We have some renewals of Lines of Credit that we renew without reviewing their financial information. When we report these loans should we use code 3 under Revenue or should we use the code we used the last time we reviewed their financials?

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#1700964 - 05/18/12 12:17 PM Re: Renewals DCollins
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Do you know the prior year gross sales/revenue? If you do not request or obtain it in some way you would report 3. It is to the banks advantage to ask "what were gross sales last year".
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1701005 - 05/18/12 01:18 PM Re: Renewals Kathleen O. Blanchard
DCollins Offline
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DCollins
Joined: Oct 2001
Posts: 707
Yes, we would know what the prior year was. If we know that should we use that amount instead of code 3?

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#1701018 - 05/18/12 01:35 PM Re: Renewals DCollins
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Yes, because you report the gross revenue for the prior full year. So on a loan now, you report 2011 revenue.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1701199 - 05/18/12 05:27 PM Re: Renewals DCollins
CRAatBOK Offline

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Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
Make sure you have documentation to back it up. We got blasted (had to scrub over 1,000 files) because we were reporting revenues based on what the borrower "told" us. The OCC even wanted to not count the borrower's had written FS, they wanted tax returns instead. Hopefully your examiners are not this insane and actually read the reg where it says that the bank does not have to verify income.

Gee, this was 5 years ago and it still burns me.
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Life is not the way it's supposed to be. It's the way it is. The way you cope with it is what makes the difference.

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