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#1785816 - 02/13/13 09:06 PM Is A Family Trust CRA Reportable?
txgal, CRCM Offline
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Joined: Jul 2006
Posts: 44
Texas
I have a loan under $1 million that is commercial real estate property in the name of John Smith Family Trust. Can this be CRA reportable?

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CRA
#1785822 - 02/13/13 09:11 PM Re: Is A Family Trust CRA Reportable? txgal, CRCM
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Yes. If the loan is secured by non-farm non-res real estate, and is $1 million or less it is a small business loan for CRA.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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#1785838 - 02/13/13 09:34 PM Re: Is A Family Trust CRA Reportable? Kathleen O. Blanchard
txgal, CRCM Offline
Junior Member
Joined: Jul 2006
Posts: 44
Texas
Thank you! smile

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#1785893 - 02/13/13 10:51 PM Re: Is A Family Trust CRA Reportable? txgal, CRCM
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
This is determined by how the loan is reported on the Call Report. For loans secured by non-farm non-residential real estate, purpose of loan and type of borrower have no bearing. The classification is totally collateral based.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1786629 - 02/15/13 03:42 PM Re: Is A Family Trust CRA Reportable? Kathleen O. Blanchard
JustGottaKnow Offline
Member
Joined: Aug 2008
Posts: 77
What about an indirect automobile loan in the name of a family trust? They are coding it as c&i 04A0 just because it is in the name of the trust. The purpose is to purchase a vehicle with the vehicle as collateral. Do not have what the vehicle is actually being used for.

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#1786644 - 02/15/13 03:54 PM Re: Is A Family Trust CRA Reportable? txgal, CRCM
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Call code 4 (C&I) has to have a business purpose. If that is how the bank is treating this, then that is how you report. Your only recourse is to review coding with those who established the bank's coding (lending and finance).
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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