Skip to content
GeoDataVision
Thread Options Tools
#36321 - 10/09/02 01:49 PM CRA reportable?
Some Days You Just Can't Win Offline
Gold Star
Some Days You Just Can't Win
Joined: Feb 2002
Posts: 461
Mississippi River Valley
I need some help in determining whether or not a loan is CRA reportable or not.

I have reviewed the CRA Loan Data Collection Grid, http://www.ffiec.gov/cra/pdf/cra_loandatagrid.pdf , as well as the CRA Guide, http://www.ffiec.gov/cra/pdf/cra_guide.pdf. I am having a hard time confirming this is not a reportable loan.

It's a small business loan for construction of a new auto facility with a six month term.

I am thinking that it currently would not be CRA reportable because it is in the construction phase with a short term. It would be reportable when the project is completed and the note is termed out.

Thoughts/comments???? Do you know where I can specifically find a cite in either document or the regulation?

Thanks in advance........

_________________________
How long a minute is depends on what side of the bathroom door you're on.

Return to Top
General Discussion
#36322 - 10/09/02 04:43 PM Re: CRA reportable?
CalifDreamin Offline
Diamond Poster
CalifDreamin
Joined: Mar 2002
Posts: 2,237
Far from Calif
First check to see how it will get reported on your call report....
_________________________
The opinions expressed are mine and do not necessarily reflect those of my employer
_._._._._._.
A.S.A.P.
Always
Say
A
Prayer
<><

Return to Top
#36323 - 10/09/02 08:57 PM Re: CRA reportable?
Anonymous
Unregistered

I may have read the question wrong but perhaps there is some confusion with CRA and HMDA reporting requirements.

Given that all other requirements of a Small Business Loan have been satisfied, you might be able to report this twice. Once this year as a new loan for the full credit amount. and again next year when its rolled over to amortized financing.


Return to Top
#36324 - 10/10/02 01:38 AM Re: CRA reportable?
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Construction loans do not get a Call Code of 04a or 01e. I think they are 01a but I'm going off of memory which can be a dangerous thing.

So - the construction loan for the auto facility is NOT a small business loan. The next step is to look for any Community Development benefit. Is the facility being built in an Enterprise Zone, or will it help revitalize or stablize a low-mod area?

Your take out loan will probably be reported as a small business loan if the loan amount is $1Million or less.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#36325 - 10/10/02 08:09 PM Re: CRA reportable?
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
I'm assuming we're talking about a loan that is below one million dollars? If so, I think the following information applies....

according to the FFIEC "A Guide to CRA Data Collection and Reporting" page 12,

"Data collected in 2001 and subsequent years...An institution should collect information about small-business and small-farm loans that it refinances or renews as a loan origination. (A refinancing generally occurs when the existing loan obligation or note is satisfied and a new note is written, while a renewal is an extension of the term of a loan. However for purposes of small business and small-farm CRA data collection and reporting, it is no longer necessary to distinguish between the two.) When reporting small-business and small-farm data, however, an institution may report only one origination (including a renewal or refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted."

If your Construction line was for x amount of dollars and was not increased when the permanent financing was granted IN THE SAME YEAR I believe you would report this as just one loan. If however, there was an increase, the increased amount would be the amount of the second loan reported.

http://www.ffiec.gov/cra/guide.htm

I have an examiner here who agreed with me (actually we've got about 20 of the darned things here). You might want to call your own if you still aren't feeling comfortable with the answer. The key in my mind hedges on the two loans booking the same year for the same dollar amount.

If we're talking a CD loan, I've already run the idea of getting double credit for the loan and line with the new data collection guidelines by my examiner. (just for giggles) He umm...giggled!

Hope that helps!
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

Return to Top
#36326 - 10/11/02 12:54 AM Re: CRA reportable?
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Dawnie - the Call Report instructions very clearly state that a Construction Loan is NOT to be reported as a small business loan. Therefore, a construction loan should not be reported on the CRA Loan Register.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#36327 - 10/11/02 06:58 PM Re: CRA reportable?
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Bonnie: I think I spent too much time talking CD benefit verses reporting and twisted myself. Sorry! The answer still falls as "one loan" but the line wouldn't matter in regards to term as it's construction. My bad!

One the other hand, you could still take the line for CD credit if you weren't claiming the take out deal later if it had CD value. If you get the take out financing...it's just one CD loan as well though. (We do alot of construction that is taken out by HUD or another entity).

Thanks for the catch!
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

Return to Top
#36328 - 10/11/02 07:38 PM Re: CRA reportable?
Tina A Sweet Offline
Diamond Poster
Tina A Sweet
Joined: Aug 2001
Posts: 1,033
Marysville, Ca.
Brenda, BDyess has the knowledge in this area. She is also very knowledgable in HMDA.
_________________________
Tina A Sweet-Williams
AVP Special Assets
mailto:tsweet@goldcountrynb.com

Return to Top
#36329 - 10/15/02 10:57 PM Re: CRA reportable?
CalifDreamin Offline
Diamond Poster
CalifDreamin
Joined: Mar 2002
Posts: 2,237
Far from Calif
Thanks for the vote of confidence!

I will say though that it has been about a year since I was actively involved in CRA - getting back into it now, though...
_________________________
The opinions expressed are mine and do not necessarily reflect those of my employer
_._._._._._.
A.S.A.P.
Always
Say
A
Prayer
<><

Return to Top