Thread Options
#2182189 - 06/18/18 09:00 PM Moved from ISB to large bank
Lori01 Offline
100 Club
Joined: Jan 2007
Posts: 138
VT
I have worked at an ISB for many years and just moved to a new job at a large bank. Trying to retrain my brain on certain things, and occasionally getting myself all confused.

CD loan: if a loan qualifies as a both a CD loan and/or a small business loan, is it my choice to report it as a CD loan (and not a small business loan)? Or, because it qualifies as a small business loan, am I forced to report it that way and therefore can not report it as a CD loan?

Other than mandatory reporting (which I did in my ISB anyway) and that the CRA exam has three parts to it instead of two, what other big ticket items should I be on the lookout for that are different as a large bank verses a ISB?

thanks!

Return to Top
CRA
#2182252 - 06/19/18 02:12 PM Re: Moved from ISB to large bank Lori01
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,572
Originally Posted By Lori01
what other big ticket items should I be on the lookout for


While in theory this shouldn't be an issue, I would be concerned if I switched agencies and was going to deal with a new regulator. From my reading of CRA evaluations over the years, each regulator takes a slightly different approach to their evaluations. Therefore, you might consider reading several large bank evaluations from your current regulator as you will start to get a feel for what they are looking at and what can be considered during your evaluation.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2182284 - 06/19/18 03:16 PM Re: Moved from ISB to large bank Lori01
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 764
Originally Posted By Lori01
I CD loan: if a loan qualifies as a both a CD loan and/or a small business loan, is it my choice to report it as a CD loan (and not a small business loan)? Or, because it qualifies as a small business loan, am I forced to report it that way and therefore can not report it as a CD loan?


If it qualifies as a small business loan you are required to report it in your CRA LAR and it is not eligible to be considered as a community development loan.

Return to Top
#2182387 - 06/19/18 09:34 PM Re: Moved from ISB to large bank Lori01
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
ISBs have the flexibility to choose between considering a loan as small business or as Community Development because ISBs have a separate Community Development component of their CRA Exam.

Large Banks lose that flexibility and must report all loans that meet the definition of "Small Business" as Small Business now matter how much Community Development is created by that loan. As an example, you make a $500,000 loan to a non-profit day care facility in a low income neighborhood whose mission is to provide child care and education to low- and moderate-income families and take a lien on the day care facility property.

Since the loan is secured by non-farm, non-residential real estate and the loan amount is not greater than $1Million, it meets the definition of a small business loan and you must now report it as a small business loan. Sure you could dress it up in your Performance Context and Self-Evaluation, and your examiner would probably give you an "attaboy" for it, but it won't be counted as Community Development.

If the loan were greater than $1MM, AND/OR if you did NOT take the property as collateral, then it would NOT meet the definition of small business loans (because loans to non-profit organizations are not classified as small business on your call report UNLESS the loan is secured by non-farm non-residential real estate) and therefore you could classify it as Community Development.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#2182662 - 06/21/18 07:18 PM Re: Moved from ISB to large bank Lori01
Lori01 Offline
100 Club
Joined: Jan 2007
Posts: 138
VT
Thank you for this information Princess Romeo. It helps clear things up for me.

Adam: I didn't switch agencies, just the size of the bank I work for. Trying to wrap my head around what that means in terms of different exams....going from a ISB to a large. My new employer has been a large for a while, so I need to get up to speed on any differences I need to retrain myself on from my years working for an ISB.

Any other examples or thoughts are welcome.

Return to Top