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#2102079 - 10/06/16 03:17 PM Construction to Permanent Loan CRA?
bnkgrl77 Offline
Junior Member
Joined: Mar 2012
Posts: 30
Illinois
We have a loan is under $1 million for cost overruns on a construction project. The loan is structured as a construction to permanent loan with one closing. I know that the construction piece is not reportable. However when the loan moves to permanent financing and changes IGL code to a small business loan for the call report does it then become CRA Small Business reportable?

Thanks in advance!!

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CRA
#2102138 - 10/06/16 05:37 PM Re: Construction to Permanent Loan CRA? bnkgrl77
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
If the loan will be secured by non-farm non-residential real estate (reported on line 1 e 1 or 1 e 2 of the Schedule RC-C1 of the Call Report) or some other collateral and reported on line 4/4a, yes it will be small business.

Type of borrower, type of collateral, etc. will drive where the loan is for the Call Report and therefore for CRA.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2103913 - 10/20/16 05:06 PM Re: Construction to Permanent Loan CRA? bnkgrl77
terpsfan Offline
Diamond Poster
Joined: Feb 2007
Posts: 1,993
What action date would be reported for a construction perm one time close? Would the permanent phase be a reportable loan for CRA since there is no renewal or refinance involved?

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#2178112 - 05/15/18 02:29 PM Re: Construction to Permanent Loan CRA? Kathleen O. Blanchard
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 105
San Antonio, TX
What happens if the loan doesn't convert to permanent financing until the next calendar year or later? Can we report it for the year in which it goes to perm (years following the note date), or is it lost due to it not occurring during the same year as the note date?

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#2178114 - 05/15/18 02:31 PM Re: Construction to Permanent Loan CRA? Help! Compliance
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 105
San Antonio, TX
...speaking of the CRA LAR (not HMDA)

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