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#2212759 - 05/02/19 11:14 PM Guide to CRA Data Collection and Reporting
Bville Offline
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Bville
Joined: May 2001
Posts: 1,282
Out West
Has the FFIEC's Guide to CRA Data Collection and Reporting been updated since 2015? If has anyone have a link to share?

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CRA
#2212783 - 05/03/19 03:39 PM Re: Guide to CRA Data Collection and Reporting Bville
Bville Offline
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Bville
Joined: May 2001
Posts: 1,282
Out West
What I really want to know is if there is still a CRA Code Type 4 (Home Equity). It seems like there should not be. Is there a Filing Instruction Guide for CRA?

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#2212937 - 05/07/19 01:56 AM Re: Guide to CRA Data Collection and Reporting Bville
Reads Regs Offline
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Joined: Nov 2004
Posts: 2,290
The guide hasn't been updated since 2015. There was an informational letter in 2016 that said to use the 2015 guide for 2016 CRA data.
https://www.ffiec.gov/cra/pdf/2016_CRA_Guide.pdf

The CRA file specs for 2019 mentions code 04 home equity. https://www.ffiec.gov/cra/pdf/2019Specs.pdf

If you are a HMDA reporter, you would be reporting all of your closed end credit home equity loans secured by a dwelling and your HELOCs if you exceed 500 on your HMDA LAR. Could code 04 perhaps still be available for an institution that didn't have to put their HELOCs on the HMDA LAR and chose to collect some data for those loans under CRA?
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

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#2212975 - 05/07/19 02:06 PM Re: Guide to CRA Data Collection and Reporting Bville
Bville Offline
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Bville
Joined: May 2001
Posts: 1,282
Out West
Thank you! I expected the 04 code to be gone since the phrase "home equity" was removed from the definition of "consumer loan."

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