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#2094224 - 08/19/16 02:51 PM CRA Loan Data Collection Grid - Clarification
Tennismom Offline
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Tennismom
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Looking at the CRA Loan Data Collection Grid https://www.dallasfed.org/assets/documents/cd/pubs/craloan.pdf, I am trying to wrap my hands around - Loan to Non-profit secured by Residential Real Estate

"Construction and other temporary financing or the construction-only portion of a construction-permanent loan to a nonprofit entity secured by residential real estate with a primary purpose consistent with the definition of community development.", would be considered a Community Development Loan (CDL). Is this saying that if we do one note/one closing (i.e. - construction/perm loan) that it would not qualify as a CDL?

Appreciate any insight!

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#2094264 - 08/19/16 04:13 PM Re: CRA Loan Data Collection Grid - Clarification Tennismom
justsayjulie Offline
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back home again
I'm reading it to say that the "construction-only portion of a construction-permanent loan" qualifies.
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#2094279 - 08/19/16 04:45 PM Re: CRA Loan Data Collection Grid - Clarification Tennismom
Kathleen O. Blanchard Offline

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You can only count construction only or the construction phase. Is the initial construction phase carried as construction on the Call Report? If yes, you could likely report that phase. But if it is simply booked as the final phase, it cannot be counted.
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#2094305 - 08/19/16 05:17 PM Re: CRA Loan Data Collection Grid - Clarification Tennismom
Tennismom Offline
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Thanks. One other question re the Grid

If I have a permanent loan to a nonprofit entity secured by and made for the purpose of purchasing, refinancing or improving a 1–4 family dwelling, including manufactured housing with a primary purpose consistent with the definition of community development (affordable housing) does this qualify as a CDL? For example, a nonprofit to purchase 10 LIHTC 1-4 family homes to be rented at below market rate. LIHTC have income and rent maximums. Would this be a CDL? The grid only addresses multifamily housing as being a qualified CDL.

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#2094311 - 08/19/16 05:29 PM Re: CRA Loan Data Collection Grid - Clarification Tennismom
Kathleen O. Blanchard Offline

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Are the loans HMDA reportable? If yes, they must remain in HMDA and you can only "point out" the loan purpose in the exam.

Multifamily can be double reported, single family cannot.
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The HMDA Academy
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#2234688 - 04/13/20 05:35 PM Re: CRA Loan Data Collection Grid - Clarification Tennismom
Compliance NABW Offline
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I have a hard time believing that a Bank won't get Community Development credit for a loan to build affordable housing just because they decide to do a one-time close, rather than separating out the financing. Putting the grid to the side, it would seem this fits the following Interagency Q & A:

§ll.12(h)—1: What are examples of community development loans? A1. Examples of community development loans include, but are not limited to, loans to

•borrowers for affordable housing rehabilitation and construction, including construction and permanent financing of multifamily rental property serving low- and moderate-income persons;

With that being said, in a situation where a Bank executed separate financing for the construction phase and the permanent phase, does an institution report both and, in essence, get to double count? Doesn't seem right, but I can't find anything concrete regarding an answer one way or another. The Grid and the Interagency Q & A could be interpreted to support both conclusions. Does anybody know of specific guidance on this?

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#2235216 - 04/20/20 01:35 PM Re: CRA Loan Data Collection Grid - Clarification Tennismom
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I believe the answer is that the permanent phase is a refinance, so you apply the "Refinance and Renewals" rules listed in the CRA Date Collection Guide, i.e. you get credit for both if done in separate years. However, if done in the same year, then you would only get credit for any increased amount for the perm loan.

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