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#1918605 - 04/29/14 08:03 PM CD Lending originated outside of AA
Flyboat Offline
Junior Member
Flyboat
Joined: Jan 2006
Posts: 40
Was a bank able to attribute CD lending originated/purchased outside of the AA or in another state to a one of its MSA/AA in different state or region? I was approached by a senior executive who insisted that in the [distant CRA] past (20-25 years ago) his bank received credit for loans obtained from an out-of-state bank that the regulators gave them for in a different AA in a different state. I’m ready for my history lesson. Was this kind of activity permissible under the original rules when CRA was governed under the pre-1995 multiple test rules?

I've been involved in CRA for a number of years, fully understand the loans for additional consideration principle, and know that this question has been consistently NO. Despite my objections, and protestations to the contrary, he is adamant that I should be able to do this today.

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CRA
#1921204 - 05/08/14 02:30 PM Re: CD Lending originated outside of AA Flyboat
Data Offline
100 Club
Data
Joined: Oct 2002
Posts: 226
Houston
It is my experience that executives have very good memories. Nothing suprises me and I do not discount anything with CRA because at its core, CRA is reinvestment. I attend meetings througout the year with bankers and regulators working through methods of reinvestment. My counsel is to follow up with a deal the executive is working on and evaluate it. Other than than it is hard to dismiss something until you see it.
_________________________
One thing change will bring is something new.

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#1921239 - 05/08/14 03:05 PM Re: CD Lending originated outside of AA Flyboat
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Much will depend upon how responsive the bank is in its own AA. If that is fine, then other areas might count. If you review the revised q and a, you will see discussion of this point, but performance in your own AA is of utmost importance and can affect how any activity outside of the AA is treated.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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