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#1911362 - 04/03/14 06:24 PM CRA and Charged Off Loans
txgal, CRCM Offline
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Texas
We have a few loans thatwhen origally booked were coded as Community Development Loans under CRA. Because the loans became delinquent and we had to write off the remaining balance, can we still continue these as Community Development Loans or do we need to remove them from our files?

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#1911451 - 04/03/14 08:20 PM Re: CRA and Charged Off Loans txgal, CRCM
Pale Rider Offline
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If you wrote off the balance and they no longer reside in the loan portfolio, I don't know how you can still count them as CD loans.

You can certainly submit the facts of these relationships to the examiners for their consideration at exam time. But still reporting them as loans each year, when they are not loans, could be considered confusing or worse.
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#1912061 - 04/04/14 09:35 PM Re: CRA and Charged Off Loans txgal, CRCM
Trees Offline
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We had this during a recent exam. The loans were disallowed as the projects were not assisting LMIs as was the original intention.

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#1912069 - 04/04/14 09:49 PM Re: CRA and Charged Off Loans txgal, CRCM
Kathleen O. Blanchard Offline

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This will depend upon the situation. As Trees stated, if the projects did not reach completion and assist the designated population, there will be no credit. If the project did reach completion but is now not being paid back, it could count.
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#1912076 - 04/04/14 09:58 PM Re: CRA and Charged Off Loans txgal, CRCM
rlcarey Offline
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Galveston, TX
Plus charge off does not equate to that they no longer owe you money or you didn't originally extend the loan.
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#1912150 - 04/07/14 01:31 PM Re: CRA and Charged Off Loans Pale Rider
B_F Offline
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Cincinnati, OH
Originally Posted By: Pale Rider
If you wrote off the balance and they no longer reside in the loan portfolio, I don't know how you can still count them as CD loans.


But Pale, if they paid off the loan in the same year you made it, you'd still get to count them....

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#1912156 - 04/07/14 01:43 PM Re: CRA and Charged Off Loans txgal, CRCM
Pale Rider Offline
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That is a true statement B F, I assumed they were not in the same year, maybe not even in the same exam cycle. Having loans go bad within the same year may highlight some underwriting problems, especially in many markets in Texas, we are booming down here.
_________________________
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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