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#2133160 - 06/06/17 02:48 PM CRA: Brokered Loans and "Other Loan Data"
Norman Paperman Offline
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Norman Paperman
Joined: Aug 2012
Posts: 1,636
48.934476, -114.343735
Howdy BOLers,

I'd like some opinions regarding our brokered loan that we run through our mortgage operation. They table fund those loans and then sell them off to investors. The Q&A clearly states that we may have those considered under the lending test as "Other Loan Data". I've run a pivot on those loans and the breakdown between low/mod/middle/upper is pretty abysmal.

Given the heavily weighted production to upper income tracts, am I safe to assume that those are probably loans I wouldn't want to have considered as "other loan data"? In other words, will I catch more criticism for the breakdown of the tracts than praise for the origination of the loans within the AA?
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CRA
#2134085 - 06/13/17 02:41 PM Re: CRA: Brokered Loans and "Other Loan Data" Norman Paperman
CRAGoddess Offline
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Joined: Nov 2001
Posts: 36
WV
Personally, given your analysis, I would not report them. The purpose of capturing those loans and reporting them as Other Loan Data is to have them evaluated in your CRA lending performance. The Q & A states that "Examiners will consider these other loan data using the same criteria by which home mortgage loans originated or purchased by an institution are evaluated," which means how well you are lending to LMI borrowers and in LMI areas. You don't say specifically, but I assume your analysis was both on borrower and geographic distribution. Given that it wasn't great to the CRA target groups, I wouldn't.
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#2134227 - 06/14/17 01:28 PM Re: CRA: Brokered Loans and "Other Loan Data" Norman Paperman
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
I recommend only bringing in helpful data. I would give some thought to why these are so skewed to upper income. That can potentially be a problem down the road.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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#2134283 - 06/14/17 03:15 PM Re: CRA: Brokered Loans and "Other Loan Data" Norman Paperman
Norman Paperman Offline
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Norman Paperman
Joined: Aug 2012
Posts: 1,636
48.934476, -114.343735
Thank you both. Kaybee, I'll PM you about the skew.
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Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.


CRCM

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