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#1738604 - 09/06/12 07:16 PM Job Creation for LMI Documentation
Bluesfan57 Offline
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Joined: Feb 2011
Posts: 155
Peak 10 Breck, CO
we are curious as to what ways other banks are documenting job creation of low and moderate individuals when not in a low or moderate tract.

we feel that we are doing these types of loans but arent gathering the proper documentation to get credit for them. (FYI examiner is FRB Chicago)

we are hesitant to ask for a copy of payroll as we dont think that will be receptive. an idea we are kicking around.

*drafting a standard letter with simple questions..

How many employees do you have?

How many of those employees make less than 40,000(or whatever the Moderate income ceiling for the county is)?

what do you think?? or if you have any suggestions that would be great

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CRA
#1738882 - 09/07/12 02:58 PM Re: Job Creation for LMI Documentation Bluesfan57
JobSecurity Offline
Platinum Poster
Joined: Oct 2009
Posts: 604
I currently attach an email from the borrower as to expected job creation amount and wage range. That has been okay with the examiners in the past. I would also like to know how other banks are documenting this.

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#1740696 - 09/13/12 06:28 PM Re: Job Creation for LMI Documentation Bluesfan57
CRAatBOK Offline

Power Poster
Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
That is what I do Blues (only it comes from the LO or whomever else has a relationship with the borrower). Well, I should say that I send it to the LO and he/she forwards it on. Anyway, I also ask if the jobs have benefits like health insurance, paid holidays, vacation, 401K, etc.

If it is a new business I want to know how many jobs are created and if any of those employees were moved from somewhere else.
_________________________
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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#1740750 - 09/13/12 08:31 PM Re: Job Creation for LMI Documentation Bluesfan57
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
It can also be good to document any training that the company will be providing. Sometimes a firm will come to an area and hire people with little experience but show evidence of ability to understand directions, good mechanical skills (basic) etc and will train. It may be working with a local tech school to do the training. This can really provide good long term employment skills for people in the area.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1740751 - 09/13/12 08:32 PM Re: Job Creation for LMI Documentation Bluesfan57
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
It can also be good to document any training that the company will be providing. Sometimes a firm will come to an area and hire people with little experience but show evidence of ability to understand directions, good mechanical skills (basic) etc and will train. It may be working with a local tech school to do the training. This can really provide good long term employment skills for people in the area.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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