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#1884426 - 01/08/14 10:14 PM credit card lines to sm businesses
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Our card portfolio is on another system. Historically we never included these lines in our small bus. loans. We wish to start doing so with 2013 stats. As the cards are not accounted for on our cores system, we cannot add the cards to the file provided to the regulators (the one using the FFIEC standards). Can we, therefore, include these on the report we developed to account for the larger loans and which we put on a spreadsheet? We don't have a lot. maybe 25 total.

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CRA
#1884448 - 01/08/14 11:39 PM Re: credit card lines to sm businesses Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
If you file an annual CRA submision, you need to combine these loans with your other small business submissions, whether by manually adding, importing separately into the FFIEC software, etc.

If you do not file an annual submission you can have a separate report.

Either way, the loans must be geocoded and properly coded for CRA type, revenue, etc.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1884517 - 01/09/14 03:07 PM Re: credit card lines to sm businesses Trees
Trees Offline
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Joined: Apr 2005
Posts: 4,013
OK, that helps.

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