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.
Last edited by pp1865; 05/14/18 05:18 PM.