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#972072 - 06/10/08 12:30 PM Hmda or CRA?
law Offline
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Is the following HMDA or CRA reportable?

Loan to purchase a mobile home park. No mobile homes are included - just the pads - but there is one rental house in the park. HMDA? Wasn't sure since there is one house involved. or CRA?

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#972164 - 06/10/08 02:14 PM Re: Hmda or CRA? law
hmdagal Offline
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This is HMDA reportable as a home purchase because of the rental house. It may or may not also be CRA reportable - I'm not familiar enough with CRA to help with that part of the question.

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#973687 - 06/12/08 12:57 PM Re: Hmda or CRA? hmdagal
Dan Persfull Offline
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I'm not that familiar with CRA reporting either but if I'm not mistaken if the loan is secured by residential property then it does qualify as a small business loan for CRA reporting.
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#975460 - 06/16/08 12:35 AM Re: Hmda or CRA? Dan Persfull
Kathleen O. Blanchard Offline

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If the loan is on your call report as secured by residential real estate, it is only CRA reportable as a Type 3, not a Small Business Type 1 CRA loan.
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#975898 - 06/16/08 06:19 PM Re: Hmda or CRA? Kathleen O. Blanchard
CRAatBOK Offline

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Kaybee you probably should clarify that the loan is actually classified as a type 3, which is not reportable under CRA. Type 3 loans can be included by the bank for examiner review during the exam. If the loan was reported as commercial RE on the Call Report then it is a type 1 for CRA and reportable under CRA.
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#976193 - 06/16/08 11:34 PM Re: Hmda or CRA? CRAatBOK
Kathleen O. Blanchard Offline

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True...type 3s are reportable when your examiners show up. You can put your type 3's in front of them and they will include them in the exam.
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#976219 - 06/17/08 02:27 AM Re: Hmda or CRA? Kathleen O. Blanchard
Len S Offline
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Connecticut
You've got to be careful with the language used here. The only loans "reportable" under CRA are small business, small farm and community development loans. Other loans, including small business "other" lines/loans, home equity loans, auto loans, etc., may be collected (in fact there is a loan type field in the FFIEC CRA software) and included in a CRA performance evaluation if you exercise your elective or if in an examiner's opinion the omission of the loan type would distort a bank's CRA performance. Ironically, the "micro data" is never reported, including the small business loans. The small business and small farm loans are compiled and reported in different "panels" that summarize the data by census tract, etc.
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#977918 - 06/19/08 01:47 PM Re: Hmda or CRA? Len S
CRAatBOK Offline

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Further South than I wanna be.
Just what is this "micro data" that you are refering to?
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#977924 - 06/19/08 01:50 PM Re: Hmda or CRA? CRAatBOK
Mrs. Rizzo Offline
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Curled up by the fire...
I think he's referring to all that other data you can collect but don't report...like a small business loan secured by a SFR.
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#979545 - 06/20/08 10:52 PM Re: Hmda or CRA? Mrs. Rizzo
CRAatBOK Offline

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Further South than I wanna be.
Oh Lenny, where are you????
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#979585 - 06/21/08 03:23 AM Re: Hmda or CRA? law
Len S Offline
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"Rizzo is right"! but only partially.

Most bankers think that all the small business loans they originate or purchase are reported as individual records as is done with applications reported under HMDA. But no individual loan records are reported under CRA. Rather what is reported under CRA are "panels" of data compiled by census tract for reportable small business or small farm loans. All the individual loan records are maintained in the "micro data" that are collected but not reported under CRA. The only loan information that is reported under CRA in reality are compilations of the reportable loan information (small biz, small farm and CD loans). The individual small business and small farm loan records reside in the micro data file that stays in your files on your computer. In fact, the filing instructions tell you not to send the micro data file. If you voluntarily collect information about non-reportable loans those records also are retained in the micro data file. When examiners arrive for your CRA PE they will request the micro data file as part of the exam.
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#980368 - 06/23/08 08:51 PM Re: Hmda or CRA? Len S
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Further South than I wanna be.
Thanks Len, that really clears things up.
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