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#2240839 - 08/10/20 04:50 PM Loan Less Than $500
TMatt87 Offline
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TMatt87
Joined: May 2011
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Idaho
We had two PPP loans with loan amounts less than $500. I know for HMDA, loans less than $500 are not reportable, as they would be rounded down to $0. However, I've looked through the CRA Q&As and the reporting guide, and couldn't find a similar exemption for CRA. It makes sense not to report, because the amount would be $0, but I guess they didn't think this situation would ever come up. Any advice?
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#2240843 - 08/10/20 05:38 PM Re: Loan Less Than $500 TMatt87
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,310
Galveston, TX
It has been a while since I have been actively involved in CRA compliance, and maybe this has just blown right over my head, but there is a reporting requirement at the individual loan level for CRA data reporting?
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#2240848 - 08/10/20 07:09 PM Re: Loan Less Than $500 TMatt87
TMatt87 Offline
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TMatt87
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Idaho
It's not a lot of information, but large banks have to report loan number, loan amount, whether the loan is a small business or small farm loan, and whether the business/farm revenues are greater than 1MM:

228.42
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#2240849 - 08/10/20 07:25 PM Re: Loan Less Than $500 TMatt87
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,310
Galveston, TX
Right - that is data to be maintained - there is no rounding. You only round when you are reporting the aggregate categories.
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#2240850 - 08/10/20 07:46 PM Re: Loan Less Than $500 TMatt87
TMatt87 Offline
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TMatt87
Joined: May 2011
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Idaho
Hmm, my CRA reporting software (Questsoft) requires the loan amount to be expressed as rounded to the nearest thousand. I did find that there's a checkbox for a loan amount less than $500.
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