Skip to content
BOL Conferences
Thread Options
#2247630 - 01/13/21 07:43 PM Purchased Loan Portfolio
frumpette Offline
Junior Member
Joined: Sep 2009
Posts: 46
We purchased a portfolio of consumer loans in mid-2020. We bought the asset and the servicing. Because we didn't actually originate these loans do I exclude them when I'm evaluating our lending performance? (We're an ISB, so this is just for our In/Out analysis)

Return to Top
CRA
#2247673 - 01/14/21 04:54 PM Re: Purchased Loan Portfolio frumpette
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
Ordinarily, consumer loans are not evaluated in CRA PE's unless the data constitutes a major product line and its omission would materially distort the bank's record or you want to voluntarily submit your consumer loans for CRA examination purposes (this would require your edit checking and scrubbing the data to assure its integrity). So, your question would be a non-issue in most situations. Have examiners mandated the inclusion of consumer loans in previous exams or have you voluntarily submitted consumer loans for CRA evaluation purposes?
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

Return to Top