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#2149833 - 10/14/17 08:02 PM Lot purchase and Construction
Bec Offline
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Just want to make sure my thoughts are correct on this.
A loan for the acquisition of a lot and the construction of a future Dunkin Donuts would not be reportable for CRA purposes correct?
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#2149946 - 10/16/17 05:39 PM Re: Lot purchase and Construction Bec
Tennismom Offline
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You are correct. It falls on the CALL Report as a line item # A1a2 - Other construction loans and all land development and other land loans, which is not CRA Small Business Reportable item.

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#2149947 - 10/16/17 05:46 PM Re: Lot purchase and Construction Bec
Bec Offline
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Thank you, additional, non-related follow up question,
If I have loans that I think should be on the Small Business reporting side of things for CRA but they are not on the call report, does that mean I cannot report them? I mean, I guess the first question is why would something that, on the outset, would appear to fit the criterion not be on the call report? I am new to this, so if anyone has any thoughts, they would be greatly greatly appreciated. It seems like this should be easier that it is for me right now.
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#2149954 - 10/16/17 06:28 PM Re: Lot purchase and Construction Bec
NMB Offline
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You may want to gather any guidance the loan support staff uses to assign call report codes. Also, find out who prepares schedule RC-C and use them as a consultant. If incorrect call report codes are being assigned occasionally, this should be corrected and some training initiated. If the guidance is giving incorrect information, then a discussion with the call report staff might be in order.

When starting two different banks on large bank reporting, checking how call report codes were assigned was one of my first tasks. At both banks some unexpected coding was taking place due to incorrect interpretations.
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#2149972 - 10/16/17 07:44 PM Re: Lot purchase and Construction Bec
Bec Offline
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Cool, I'll get together with the call reporting people. Would the best approach be to take the loans that I think should be coded on the RC-C schedule and reverse engineer it as to why they are not being reported on that particular schedule? Does it matter that we have had our Call Report audited and there were no apparent findings.
If a loan is not on the call report, does that mean it can't be reported on the CRA?
Thanks!
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#2149978 - 10/16/17 08:17 PM Re: Lot purchase and Construction Bec
NMB Offline
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Auditors aren’t usually going to catch ever misclassified loan. I would probably start with any written guidance and work backwards to the call report staff. At a former bank, there was wide-spread misunderstanding of a particular call report issue. If I reported the loans properly for CRA I would be ignoring how they were reported on the call report. Our independent compliance consultant agreed that the call reporting was incorrect and said I should report them correctly for CRA, which I did. It took almost a year for me to convince the call report staff to change.

Hopefully you won’t find anything that extreme – just a few miscoded loans.
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#2149994 - 10/16/17 08:29 PM Re: Lot purchase and Construction Bec
Bec Offline
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LOL, me too. Sounds like that could be a large feat.
So far most of the loans have been lining up quite nicely. Just a few that I would think are reportable that aren't on the call report.
Thanks so much for relaying your experience. It helps a great deal to this newbie
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#2150057 - 10/17/17 01:59 PM Re: Lot purchase and Construction Bec
Bec Offline
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So it turns out that the reason the note was not on the call report was because it had a zero balance. We would still report that then, wouldn't we? The loan fits the definition of a Small Business loan.
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#2150089 - 10/17/17 03:32 PM Re: Lot purchase and Construction Bec
NMB Offline
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What was the loan amount or maximum line amount approved for? That is the amount to report, when it is originated, renewed amended or refinanced.

Under normal circumstances, I do not test call report status by actually checking the back-up to the call report. I get some custom reports from the loan reporting system to check on the reasonability of call report codes, collateral code, loan type code, etc.. Throw in revenue and geocode address fields, and you can build a nice data base of loans to scrub small business/small farm loans.
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#2178108 - 05/15/18 02:21 PM Re: Lot purchase and Construction Tennismom
pp1865 Offline
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San Antonio, TX
While we have come to a consensus on how to report One-time Closes for HMDA, which is at the inception of the loan, we are trying to determine how we would approach OTC's for the CRA LAR. We use to report such loans when they went to perm for both HMDA and CRA, but it was determined that this was not the best practice, at least when it comes to HMDA. We thought about reporting CRA reportable OTC's at inception as we are now doing HMDA, but then how would we report the FDIC Call code as they are 101's (1.a.(2)'s) until they go to perm, in which case they would then become reportable 102's or 107's (1.b.'s or 1.e.(1/2)'s). When it comes to the FDIC code, I don't know if we can so readily report what these loans will be in the future, so do we stick with reporting CRA LAR OTC's only when they go to perm? If we do, then we can't always report due to crossing over years, right? How is everyone else approaching this? Obviously, numbers are much less than HMDA due to loan amounts having to be less than or equal to $1 million.

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