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#2094126 - 08/18/16 09:32 PM loans reported on microdata reports-urgent!!
Trees Offline
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Posts: 4,013
We are having some differences of opinion. What are the parameters that define whether or not the loan should be included in the microdata reports versus the Community Development "spreadsheets" for CRA examinations?
There has to be a limitation or two that qualifies a loan from one report or the other. We thought it was loan amount or revenue but we are seeing loans in excess of $1 million and/or revenue in excess of $ 1 million reported in previous years' microdata reports. Reviewed the FAQs and they are not clear on this point.

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#2094137 - 08/18/16 10:45 PM Re: loans reported on microdata reports-urgent!! Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I am not sure what you are asking.

For CRA you have small business/small farm loans, HMDA, and then "everything else". The "everything else" loans are the non-small business/small farm loans and non-HMDA loans that you choose to report to make the case that you are serving your communities.

There are CRA codes for everything except HMDA reportable.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2094169 - 08/19/16 12:52 PM Re: loans reported on microdata reports-urgent!! Trees
kansas9839 Offline
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Joined: May 2016
Posts: 43
Trees, what are you trying to classify the loans as? Affordable Housing, Economic Development, Revitalize/Stabilize, or Community Services to LMI Individuals? I have a spreadsheet that I can send you breaking out the parameters that are measured and it will give you a basis of where to start. It is broken out in a language that helps me understand.

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#2094179 - 08/19/16 01:29 PM Re: loans reported on microdata reports-urgent!! Trees
Trees Offline
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Joined: Apr 2005
Posts: 4,013
For the micro data reports, using the FFIEC specs, we need the parameters for the small business loans. Not the "everything else" loans.
We were looking for the definition of what falls into the small business category and that would be reported in the FFIEC specs reports.
We've done this for years but we hit an error in the program this year. We are showing loans in excess of $1 million and with revenues in excess of $1 million. When I look at the spec sheets and FAQs etc, the loan amount is maxed at $ 1 million but revenue can be higher than $1 million. I think this is right but want to double check. Thanks.

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#2094193 - 08/19/16 02:04 PM Re: loans reported on microdata reports-urgent!! Trees
kansas9839 Offline
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Joined: May 2016
Posts: 43
I could be wrong but it can't be classified as small business if revenue exceeds 1 million. It could be classified as economic development as long the revenue for the loan is lower than the classification in NAICS for total revenue. If you don't have that information, you could look at NAICS info for # of employees vs total # of employees for the company. But I am only relatively new to the business so I would see if Kathleen or someone else might be able to provide better insight.

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#2094276 - 08/19/16 04:41 PM Re: loans reported on microdata reports-urgent!! Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Okay. For small business, you only take loans in the time frame that you are working with, that are reported as small business on schedule RCC-2. This means loans from lines 1e1, 1e2, and 4/4a on schedule RCC-1.

The small business loans are a subset of loans on those lines. Filter for the time frame you want, and remove all that are over $1 million.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2094547 - 08/22/16 05:35 PM Re: loans reported on microdata reports-urgent!! Trees
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Thanks, all. Your responses were very helpful.

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#2094555 - 08/22/16 06:03 PM Re: loans reported on microdata reports-urgent!! kansas9839
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
To clarify: revenue does not affect the classification as small business. If the loan is the correct type, and is $1 million of less, and revenue is greater than $1 million, the loan will be CRA Type 1 with revenue code 2.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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