Hi All-

We report consumer loan data for CRA consideration. Should a construction (or bridge) only loan to a consumer or individual (not a business entity) to construct, or finance the transition into, a 1-4 personal residence be included in my optional consumer loans reporting log for CRA purposes? I'm struggling with concluding whether these types of loans would be excluded from the definition of consumer loans as defined in 228.12(j).... I'm thinking yes, but I thought I'd put it out here for discussion. Thanks!!!

You would have to find out how the loan is being reported on your call report. If it is being reported as a consumer loan on your call report then it would be reported, but if it is being reported under HMDA that would cover your reporting requirement for the loan. Might make it easier to see what the collateral is--if it's a personal line of credit--then it's easy to assume that is a consumer product.

Thanks!! Call Reporting is the path I'm investing. I think that's where the answer lies. The loans in question aren't permanent financing so I was able to rule HMDA out.