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#2132881 - 06/02/17 03:01 PM Unsecured LOC for general business and repairs
peony Offline
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peony
Joined: Mar 2013
Posts: 250
We have a loan that is a unsecured LOC for general business and repairs to rental properties - I am thinking it's CRA reportable because it will be coded a business type code instead of a construction code which would show up on our Call reports as a business loan instead of a construction loan. For some reason, my loan processor is thinking it's not CRA reportable because it is listed in the loan purposes that loan is being used for repairs to rental properties. She said that if the loan is for construction or home improvements/renovations, it is not CRA reportable.

Thoughts?

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CRA
#2132929 - 06/02/17 05:01 PM Re: Unsecured LOC for general business and repairs peony
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
IMO your processor is incorrect. CRA reporting is driven by call reporting. If the loan is classified as a small business loan, presumably tying to 4a of the RC-C, and the loan is for renovations/improvements to improve rental properties or improve and sell I would consider it a small business loan. (assuming under $1MM and not to a non-profit)
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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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#2134318 - 06/14/17 04:17 PM Re: Unsecured LOC for general business and repairs peony
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
This would be a 4a C&I loan) on the call report and therefore a small busness loan for CRA if $1 million or less.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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www.kaybeescomplianceinsights.com

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