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#2053072 - 12/08/15 06:28 PM Reporting CD loans in year after originated
Pale Rider Offline
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Can we not present for consideration to examiners a CD loan purchased in 2014 for example, but not reported until 2015 or 2016 even? Assuming the exam period is 2014-2016 and the exam will start in mid-2017.
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#2053081 - 12/08/15 06:37 PM Re: Reporting CD loans in year after originated Pale Rider
JC (Darth HMDA) Offline
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Hi Pale,

We would report in the year purchased, I am not sure how it would be reported the year after (you probably know better than I).

However, if the exam period is 2014-2016 it would be included either way. Are you concerned about CD loans per AA per year? How are you reporting the year after purchase?
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#2053106 - 12/08/15 07:30 PM Re: Reporting CD loans in year after originated Pale Rider
Pale Rider Offline
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Thanks for responding quickly Smalls! I have an internal reporting person tell me the loan can't be reported at all if it wasn't reported in the year of purchase. It was an oversight. The bank did 4 large acquisitions in the last couple of years and we are still coming across possible CD loans.
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#2053107 - 12/08/15 07:33 PM Re: Reporting CD loans in year after originated Pale Rider
Kathleen O. Blanchard Offline

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I have experienced examiners throwing out CD loans that were not reported in the original year that they should have been reported. It is worth a try, of course to get it considered in the next examination.

Is your intent to resubmit with correct data or to add in to this year's submission or to simply present in the next exam?
Last edited by Kathleen B; 12/08/15 07:34 PM.
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#2053145 - 12/08/15 08:58 PM Re: Reporting CD loans in year after originated Pale Rider
JC (Darth HMDA) Offline
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Agree with KayBee - I would certainly present it to the examiners and explain the circumstances. Especially with that many acquisitions - I would hope they would be understanding.The worst they can do is throw it out. It's not required for CRA reporting - so it wont affect the data integrity portion of the exam.

I don't think I would add it into the 2015 data you're going to report (just my opinion) but I would save the information and present it to the examiners. Our examiners gave us credit for a couple we found that were not submitted in our original data, but we all know that examiners vary by area (or from exam to exam).

Best of luck!
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#2053157 - 12/08/15 09:17 PM Re: Reporting CD loans in year after originated Pale Rider
Pale Rider Offline
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Thank you, I am now approaching some of these loans as being modified subsequent to the branch acquisitions, and therefore still reportable. The acquisition of the loans and any subsequent renewals would be within the same exam period.
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#2053201 - 12/09/15 12:07 AM Re: Reporting CD loans in year after originated Pale Rider
Len S Offline
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Connecticut
Don't ever deliberately report erroneous information - if you lose credibility with examiners your troubles are just starting. I can tell you that based on my experience advising many banks, I am convinced that many legitimate CD loans are not recognized or reported because many bankers do not understand what constitutes a qualified CD loan. Moreover, all too often bankers don't collect the documentation necessary to sustain the qualifications of CD loans they do claim
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#2053202 - 12/09/15 12:22 AM Re: Reporting CD loans in year after originated Len S
Kathleen O. Blanchard Offline

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Agreed.
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#2053281 - 12/09/15 03:58 PM Re: Reporting CD loans in year after originated Pale Rider
Pale Rider Offline
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under the Lone Star
Thank God I don't deal with regulators any longer, my filter and tolerance levels are gone and I would dump on them in a heartbeat.
_________________________
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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