Hello. Our institution is considering collecting optional loan data specifically loan type 03 = Other Lines/Loans for Purposes of Small Business and loan type 04 = Home Equity Loans. If we choose to do this, must we report all types of loans that fit these categories that are otherwise not a reportable HMDA (in the case of HELOC's we've chosen not to report on our HMDA LAR), SBSF, or meet the qualifications of a Community Development loan?

Not sure I understand. But I have a question. If you are electing to report but thinking about not reporting all loans in the type why are you going to report at all?

I'm sure I'm not understanding your question correctly

Another way to ask is, can a bank only report loans originated in these categories that are in a low or mod census tract or to a low or mod applicant?

No, if you are collecting the data, you will need to collect all data. This information will be reviewed along with your HMDA and CRA data at exam time. If you have enough data the regulators may do some type of data integrate to insure the data is accurate. So you want to make sure you are collecting all the data and the data is clean.

Bubs is correct you must report all the data. Selective reporting is not an option. If examiners find you have not reported correctly, it becomes an expensive labor intensive task to rescrub a couple years worth of data and resubmit your data.

Thanks to both!

We highly recommend to all our clients to voluntarily collect and monitor the non-reportable loans because it allows you to monitor their performance and how they may affect your CRA PE if you decide to exercise your elective to include them in your CRA PE. The requirement is that you must include all loan originations within a portfolio type (no cherry picking allowed!). But you don't have to include all portfolio types in a CRA PE.

When reporting optional loans, what will the land location be based on? What address gets used for reporting purposes?

Any takers on this question?

When reporting optional loans, what will the land location be based on? What address gets used for reporting purposes?

What kind of loan? Usually for " other loans" borrower main address is used.

For consumer loans it is the home address of the consumer. For business and farm loans it is the location of the HQ or where the proceeds are used.

Other Lines/Loans - Small Business
Home Equity
Motor Vehicle
Consumer Secured
Consumer Unsecured

There is a misconception that the optional loan data is reported. The optional loan data is never reported. It is collected and compiled in the CRA micro data file and stays there till you submit it to examiners (if you choose to do so).

I have been told by examiners that you are not constrained by the conventional loan types. They told me a bank could use the credit card loan field to collect information on other types of loans such as student loans.The key is to isolate loan types (if you have sufficient volume) and to monitor their potential impact on your performance. If you use a field for some other type of loan and choose to submit the information to examiners tell them in writing you are submitting the additional data to give a more complete picture of how you meet the need for credit services and tell them if you have used a loan type field for a different type of loan.

The optional loan data is collected under the categories I have listed in my earlier post as CRA micro data and will be submitted to the examiners for performance purposes. Thanks Len S