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#1873398 - 11/21/13 10:17 PM CRA - What address do I report?
Help! Compliance Offline
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Joined: Oct 2012
Posts: 105
San Antonio, TX
We have a loan collateralized by CRE, and it's purpose is to purchase a rural lot (RE) where the borrower plans to place a mobile home trailer. From what I understand, because the FDIC code is 107/1E (based on the collateral), this is a CRA reportable loan. However, I want to be sure about which address to report. When it comes to CRE loans, I have been told that one reports the address of the collateral regardless of where the proceeds are going towards; however, I believe that it may be the location of the rural lot since that is where the money is going. All resources that I have checked out don't seem to be very clear about this. Thanks in advance for your insight. New Poster

Registered: 10/16/12
Posts: 2 Just a note: The rural lot with mobile home trailer is for investment. It will not be Borrower's homestead.
Last edited by pp1865; 11/21/13 10:39 PM.
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CRA
#1873423 - 11/21/13 11:22 PM Re: CRA - What address do I report? Help! Compliance
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
So you have a loan secured by non-farm non-residential real estate, regardless of purpose.

The address to report is the borrower's main business address OR where the proceeds will be used. The bank should have a consistent process for this, not randomly vary loan by loan.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1873429 - 11/21/13 11:59 PM Re: CRA - What address do I report? Help! Compliance
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
It would seem to me that in the true spirit of CRA, you should report the address where the money will be used.

The problem comes up when funds will be used for multiple purposes but the loan is report-able because of the call code and amount. In a perfect world, you would have a data collection form that identifies the location for the primary use of the funds, and if there is no primary address, the default would be the main business address.
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#1873430 - 11/22/13 12:03 AM Re: CRA - What address do I report? Help! Compliance
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
There are many banks that do not collect a "CRA" address and that is within the rules.

Many do regularly collect a CRA address and when there is one, geocode that address.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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