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#1977544 - 11/19/14 07:09 PM Re: Loans under a guidance line/master approval li
fnblikdd Offline
New Poster
Joined: Apr 2013
Posts: 15
NY
Following up on an old conversation (07/10/13). Kathleen, you had posted the following:

If there is an actual master note under which draws and payments are made (call it what you will...master note, guidance line, etc.....that note is what is reported assuming it falls under the correct collateral/purpose categories and dollar amount. This note is a standalone legal obligation and reported on the call report and is a loan for CRA purposes (subject to caveats mentioned).

A dealer floorplan loan is generally the legal obligation; individual draws for each vehicle are repaid under terms of that note.

If on the other hand a "line of credit"" or "facility" is booked to track availability and individual notes with their own repayment terms are booked under that facility, those "subnotes" notes are what are captured for call report and CRA, subject to purpose/collateral/dollar thresholds.

I want to be sure that I am understanding this correctly.

If we have a loan that is considered to be a demand loan, there is one note for X dollars, over the course of the loan there are various drawdowns (no new notes). Should we be reporting the full amount of the note, provided it meets the guidelines?

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#1977546 - 11/19/14 07:10 PM Re: Loans under a guidance line/master approval li fnblikdd
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
Yes, in that case you report the full amount available on the loan, assuming it meets the other requirements (size, collateral, etc.)
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1977617 - 11/19/14 09:07 PM Re: Loans under a guidance line/master approval li fnblikdd
fnblikdd Offline
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Joined: Apr 2013
Posts: 15
NY
Thank you!

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