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#2150338 - 10/18/17 07:23 PM CRA Commercial Construction
Jay Offline
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Joined: Oct 2017
Posts: 10
Have a loan that is a commercial construction, the collateral being held is a specific lot for residential 1-4 family. Is this loan CRA reportable or no?

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CRA
#2150649 - 10/20/17 05:26 PM Re: CRA Commercial Construction Jay
Len S Offline
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Joined: Oct 2004
Posts: 1,982
Connecticut
No - what qualifies as a small business loan is based on the Call Report and should appear in item 1e or 4a in Schedule RC-C Part 1. Construction loans typically fall into a different category.
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#2178106 - 05/15/18 02:19 PM Re: CRA Commercial Construction Len S
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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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#2178126 - 05/15/18 02:59 PM Re: CRA Commercial Construction Jay
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 80,325
Galveston, TX
You keep asking this question. but for the life of me I can't figure out why you would be reporting these loans under CRA in the first place?
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#2178198 - 05/15/18 06:10 PM Re: CRA Commercial Construction rlcarey
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Joined: Oct 2012
Posts: 105
San Antonio, TX
Because these are not residential (HMDA) and they are CRE, we would like to add them to our CRA LAR if we can. We have in the past, but they crossed over calendar years many times (which we definitely know can't be done with HMDA), but there doesn't seem to be clear direction anywhere that states we cannot report these loans when they go to perm (converting into a CRA reportable Call Code) regardless of whether it crosses calendar years. I was having a hard time getting anyone to give us a straight answer, or even an answer at all. I did email crahelp@frb.gov, but I have yet to receive a response from them. Because there is a $1 million threshold, we get very few of these on our LAR, but we do have a few each year, and the OCC has not said anything otherwise throughout the years, but they may have never had one in their samples either. We have had a consultant say we can report them when they go to perm regardless if this takes place in calendar years after that of the Note Date, but even they express interest in hearing what others had to say, which includes Bankers Online and the FRB.

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#2178199 - 05/15/18 06:13 PM Re: CRA Commercial Construction Help! Compliance
Help! Compliance Offline
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Joined: Oct 2012
Posts: 105
San Antonio, TX
By The way, if you know of a regulatory website/reference that gives clear direction with this, a link and/or quotation would be greatly appreciated. Thanks for all that you do in giving incite/counsel.

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