Example 1: $200,000 loan originates in March and is on the CRA LAR. In October of the same year a $500,000 loan (also on the CRA LAR) is originated and pays off and satisfies the remaining balance on the $200,000 loan. Do we report the $200,000 loan and all of the $500,000 loan OR do we report the $200,000 loan and only $300,000 of the $500,000 loan OR do we report only the $500,000 loan? If we report both loans at $200,000 and $500,000 aren't we double reporting even thought the first loan was satisfied?

I'm getting hung up on "an institution may only report one origination (including a renewal of refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted."

If I understand your question, you have two options:

#1 Option
March: $200,000
October: $300,000

#2 Option
October $500,000

I prefer option #1.

At year-end we generate a duplicate account number report at which time we would identify both the $200,000 and $500,000 loans. The $500,000 loan would be changed to a $300,000 loan on the LAR and a suffix added to October's account number such as a date (example XXXXXXXX - 10/2017) as you must report unique account numbers.

I agree with Tennismom on your options, but in my world there would not be a duplicate number. The loan in October would have a unique number and unless the payoff loan originated this year was somehow caught in the validation, it would likely slip through the cracks.

Thank you both.

Tennismom - Option #1 was my initial choice as well.

RR Jen - We would not have the same unique number either. My thought is to run a report at year end with every loan on the 2017 CRA LAR that has paid off and then research how it was paid off. Luckily the number of paid offs for the year that we have to review is manageable.

That is a very good thought!