Skip to content
BOL Conferences
Thread Options
#499596 - 02/15/06 10:07 PM Reporting Renewals
JUST CALL ME CRA Offline
100 Club
Joined: Aug 2002
Posts: 133
SOMEWHERE
I need confirmation as to whether I am understanding something correctly. I am newly in charge of reporting the CRA data and other staff at the bank and I are interpreting things differently. Am I correct that renewals and refinances are now considered one and the same and are reported as long as there is the loan is not double counted in one calendar year? We have, at one time, only reported renewals if there was new money or if the note number changed. What I am reading leads me to beleive that we are short-changing ourselves.

For example, If we made a loan to ABC, Inc. for $100,000 in 2005, and then we do a renewal of that note in 2006, would we report it just as if it was a new loan? Would it matter whether or not a new note was signed? Would matter whether or not a new note number was used?

Also, if we made a loan to XYZ, Inc. in 2005 for $50,000 and then did an increase to $60,000 in 2006, my take is that we would have two options. Either to report two loans, one for the renewal of $50,000 and another for the increase of $10,000, OR, to just report one loan of $60,000. Is that correct?

I am sorry, that this is probably elementary to all of you but I really need confirmation on this issue. Thanks.
_________________________
Opinions do not reflect opinion of employer and cannot be relied upon as advise.

Return to Top
CRA
#499597 - 02/15/06 10:20 PM Re: Reporting Renewals
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
BonnieM cited this from the Q and A:

A5. An institution should collect information about small business and small farm loans that it refinances or renews as loan origination's. (A refinancing generally occurs when the existing loan obligation or note is satisfied and a new note is written, while a renewal refers to 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 only report one origination (including a renewal or refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted.
Your comment
"Am I correct that renewals and refinances are now considered one and the same and are reported as long as there is the loan is not double counted in one calendar year? "
Answer
Yes

As far as reporting 2 or just the last loan with the increased amount. IMO that's going to be up to how good your data collection is and the controls in place to catch such scenarios.
_________________________
Compliance Analysis and Research - Software for your CRA/HMDA analysis needs

Return to Top
#499598 - 02/15/06 10:32 PM Re: Reporting Renewals
JUST CALL ME CRA Offline
100 Club
Joined: Aug 2002
Posts: 133
SOMEWHERE
Thanks. I appreciate your help.
_________________________
Opinions do not reflect opinion of employer and cannot be relied upon as advise.

Return to Top