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#1850114 - 09/09/13 07:24 PM Which Address to Use
Tennismom Offline
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Tennismom
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Posts: 762
Purpose of loan is to purchase a medical office building in "A" Census Tract.

Primary collateral is medical office building in "B" Census Tract.

Which address do I use for CRA Reporting?

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#1850118 - 09/09/13 07:27 PM Re: Which Address to Use Tennismom
Tater Offline
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Posts: 607
Missouri
Whichever tract is LMI.
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#1850130 - 09/09/13 07:40 PM Re: Which Address to Use Tennismom
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,277
The reporting address is to be the main business address or the collateral address per reporting instructions. A bank needs to have a policy to do this fairly consistently. You are not expected to pick and choose loan by loan.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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www.kaybeescomplianceinsights.com

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#1850138 - 09/09/13 07:49 PM Re: Which Address to Use Tennismom
Tennismom Offline
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Tennismom
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Posts: 762
Thanks Kathleen....so what address do I use? Oh by the way, the corporate HQ is in Census Tract "C".
Last edited by tennismom; 09/09/13 07:49 PM.
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#1850158 - 09/09/13 08:06 PM Re: Which Address to Use Tennismom
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,277
You choose, but I should clarify while responding. What the guidance states is use headquarters or address where proceeds will be used (which often will match the collateral, but not always.)

From the Q and A:

"Many borrowers have street addresses
in addition to rural route and box
numbers. Institutions should ask their
borrowers to provide the street address
of the main business facility or farm or
the location where the loan proceeds
otherwise will be applied."

Also:

§ll.42(a)(3)—1: Which location
should an institution record if a small
business loan’s proceeds are used in a
variety of locations?

A1. The institution should record the
loan location by either the location of
the small business borrower’s
headquarters or the location where the
greatest portion of the proceeds are
applied, as indicated by the borrower.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1850299 - 09/10/13 11:11 AM Re: Which Address to Use Kathleen O. Blanchard
Tennismom Offline
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Tennismom
Joined: Jan 2004
Posts: 762
Originally Posted By: Kathleen B
"
§ll.42(a)(3)—1: Which location
should an institution record if a small
business loan’s proceeds are used in a
variety of locations?

A1. The institution should record the
loan location by either the location of
the small business borrower’s
headquarters or the location [b]where the
greatest portion of the proceeds are
applied, as indicated by the borrower.


Thanks. So not where the collateral resides but where the greatest portion of the proceeds will be applied. So in the example originally posed, funds are to be used to purchase property in Census tract "A".[/b]

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#1850300 - 09/10/13 11:15 AM Re: Which Address to Use Tennismom
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Yes, it often is referred to as the collateral address because often when there is a different address, it happens to be collateral being purchased with the proceeds, but it really is a "proceeds address".
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1864301 - 10/23/13 06:58 PM Re: Which Address to Use Tennismom
cheech Offline
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Joined: Jun 2010
Posts: 207
Chatsworh PA
Is there a guide to tell you what tract to use in different scenario's? Newbie here.

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#1864311 - 10/23/13 07:12 PM Re: Which Address to Use Tennismom
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
The CRA guide and Q and A are available at the FFIEC CRA website.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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