We are new to cra reporting and have a few questions:
1. If we relied on revenue stated on a financial statement for 2012 to make the credit decision - not complete year, and we don't have the prior year gross annual revenue, can we report the 2012 partial revenue or do we annualize it?

2. Do we report NA for revenue on renewals if we do not rely it? Or do we report the last revenue obtained that is in the file?

3. We will be collecting data for consumer loans - since a HI renewal loan is not HMDA reportable, can we count it for CRA if renewed (no new money)?

4. If a loan is reported for HMDA, we cannot report it for CRA unless its a multifamily dwelling loan and qualifies under a community development loan, correct?

Thanks in advance for your assistance

OK....I'll start. These are just my opinions....

We are new to cra reporting and have a few questions:

1. If we relied on revenue stated on a financial statement for 2012 to make the credit decision - not complete year, and we don't have the prior year gross annual revenue, can we report the 2012 partial revenue or do we annualize it?

Annualize....you must report the Gross Annual Revenue amount.

2. Do we report NA for revenue on renewals if we do not rely it? Or do we report the last revenue obtained that is in the file?

If there is a revenue amount in file, I think it would be hard to argue that you didn't look at it, use it, etc.

3. We will be collecting data for consumer loans - since a HI renewal loan is not HMDA reportable, can we count it for CRA if renewed (no new money)?

If you home improvement "renewal" is a new promissory note, it is a refi for HMDA.

4. If a loan is reported for HMDA, we cannot report it for CRA unless its a multifamily dwelling loan and qualifies under a community development loan, correct?

Correct

Thanks in advance for your assistance [/quote]

If the HI consumer loan is non-dwelling secured and is renewed (no new money), can we report it under CRA since it's not considered a refinance under HMDA and not HMDA reportable.

thank you

Yes...it would be in the consumer-unsecured category. Sorry...didn't pick up on the fact that the loan is unsecured.

All of our home improvement purpose loans that are not secured by dwellings go on the CRA side because we never report those loans for HMDA (don't code or classify the loans as such).

We do report our unsecured HI loans for HMDA - we code them as a HI loan in our books.

So if we originally report a new unsecured HI loan for HMDA in one year, we can report the renewal(no new money) under CRA the following year because the renewal is not reported under HMDA? Do I have it right?

thanks

Yes!! Yes you do! Because a refinance of a home improvement loan is a refinance for HMDA (is no longer a home improvement loan) and unsecured refis are not reportable.

1. If we relied on revenue stated on a financial statement for 2012 to make the credit decision - not complete year, and we don't have the prior year gross annual revenue, can we report the 2012 partial revenue or do we annualize it?

I have a slightly different opinion for number 1 and here's why.
Granted I don't know the entire situation, but in the CRA Collecting Data guide for start-up businesses it says the institution should use the actual gross annual revenue to date. Not sure if this is a start up business or not, but if it were me I would still follow this guideline as the purpose is for the public and examiners to determine if the bank is lending to the big guys or small guys. That's just my opinion, take it for what it's worth!

Just to clarify for others who see this, you are not "reporting" these loans but capturing them for presentation during an exam. Only small business type 1 and small farm type 2 are reported. Community development aggregate data is also reported. Your CRA software, whether vendor or the FFIEC software, will filter out the other categories.

I stand corrected with respect to annualizing the revenue. And thanks for the clarification about "reporting" consumer loans.....didn't really know how to say that. You said it perfectly.

The instructions say for start ups to use the gross annual revenue to date if you do not have a full year. So if there is 9 months of data, use that.

What gross revenue
should an institution use in determining
the gross annual revenue of a start-up
business?
A3. The institution should use the
actual gross annual revenue to date
(including $0 if the new business has
had no revenue to date). Although a
start-up business will provide the
institution with pro forma projected
revenue figures, these figures may not
accurately reflect actual gross revenue
and, therefore, should not be used.

So Kathleen this is probably a silly question, but since there is no option for zero dollar revenue code, on a start up business do we report income as #1 - less than/equal to $1 million since zero is less than $1 mm?

Yes. It is a very very small business!

Hello, Home improvement loans whether secured or unsecured are not CRA reportable are they? I would think they would be NR due to personal / consumer use. Please advise, Thanks, -R

Only if you are presenting your consumer portfolio, over and above the HMDA portfolio, during an exam. They are not part of a submission.

I'm still a little confused. Say for example a business individual receives a business loan for working capital and he uses 10% to repair a roof damage on his personal residence (home). The loan would not be reportable for CRA data submission due 3/1, correct? Thanks again, -R

How is the loan classified on the call report? That is the determining factor. If the loan is on lines 1e1 or 1e2 (secured by non farm non res real estate) or line 4 (c & i) and is $1 million or less it is small business type 1 for cra.