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#2252851 - 04/23/21 02:44 PM CRA Small Business & Small Farm Reporting Address
BankerProbs Offline
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Joined: Nov 2012
Posts: 9
In updating our reporting procedures there has been some debate in the correct reporting address. Is the reporting address the business headquarter's address (shipping address) or the address that benefited from the funds of the loan? Please provide a link in the regulation for supporting answer?

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#2252960 - 04/26/21 05:42 PM Re: CRA Small Business & Small Farm Reporting Address BankerProbs
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,225
Galveston, TX
https://www.govinfo.gov/content/pkg/FR-2016-07-25/pdf/2016-16693.pdf


§ ll.42(a)(3) The Loan Location
§ ll.42(a)(3)—1: Which location should an institution record if a small business loan’s proceeds are used in a variety of locations?

A1. The institution should record the loan location by either the location of the small business borrower’s headquarters or the location where the greatest portion of the proceeds are applied, as indicated by the borrower.
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#2253082 - 04/27/21 08:47 PM Re: CRA Small Business & Small Farm Reporting Address BankerProbs
COMPL101TX Offline
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Joined: Apr 2018
Posts: 108
From prior discussion on this topic, I believe the consensus was to pick one and stick with it. We use the location where the loan proceeds will be used first, then the borrower's location if necessary.

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#2253083 - 04/27/21 08:57 PM Re: CRA Small Business & Small Farm Reporting Address BankerProbs
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
During our 2020 CRA examination the regulators (FRB) stated the address was where the funds were to be used.
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#2253091 - 04/28/21 03:49 AM Re: CRA Small Business & Small Farm Reporting Address BankerProbs
Len S Offline
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Joined: Oct 2004
Posts: 2,084
Connecticut
The Regulation clearly states you have the choice of the principal office of the borrower or the use of proceeds. Examiners do expect consistency with the choice.

SECTION 228.12 Definitions
o) Loan location. A loan is located as follows:
(1) A consumer loan is located
in the geography where the
borrower resides;
(2) A home mortgage loan is
located in the geography where
the property to which the loan
relates is located; and
(3) A small business or small
farm loan is located in the
geography where the main
business facility or farm is
located or where the loan
proceeds otherwise will be
applied, as indicated by the
borrower.
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