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#1472113 - 11/24/10 12:01 AM How to Report
Dolly Nugent Offline
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Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
We made a loan in July for $120K. In October we increased the loan amount to $220K without changing the maturity date. For CRA data reporting purposes how do we report?
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Dolly Nugent
CRCM
Opinions expressed are my own.

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CRA
#1472114 - 11/24/10 12:20 AM Re: How to Report Dolly Nugent
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You can report $120K in July and $50K in October (you will have to add a suffix or prefix to the loan number for October) or just report $220K in October.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1472171 - 11/24/10 01:59 PM Re: How to Report Kathleen O. Blanchard
Rie A Offline
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Rie A
Joined: Mar 2004
Posts: 829
Maryland
I never thought of just reporting the higher amount on the last date. Interesting solution...
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#1472185 - 11/24/10 02:13 PM Re: How to Report Rie A
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
It is an easier process since it just requires filtering out the earlier loan with the same loan number and lower amount.

The FAQs state:

"The institution should report only the amount of the increase if the original or remaining amount of the loan has already been reported one time that year. For example, a financial institution makes a term loan for $25,000; principal payments have resulted in a present outstanding balance of $15,000. In the next year, the customer requests an additional $5,000, which is approved, and a new note is written for $20,000. In this example, the institution should report both the $5,000 increase and the renewal or refinancing of the $15,000 as originations for that year. These two originations may be reported together as a single origination of $20,000."

Two comments, if you don't report the earlier loan, you can report the entire loan for the increased amount "because it has not been reported earlier". The example crosses reporting years, but otherwise says you can combine.

I know quite a few banks that do this and none have been criticized. I have discussed the process with examiners and they were fine with it.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1472256 - 11/24/10 03:20 PM Re: How to Report Kathleen O. Blanchard
Rie A Offline
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Rie A
Joined: Mar 2004
Posts: 829
Maryland
I guess I was so focused on reporting the correct amounts I missed the part "These two originations may be reported together as a single origination"
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God made the world in only 7 days... but he didn't have any paperwork.

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#1473129 - 11/29/10 03:05 PM Re: How to Report Kathleen O. Blanchard
B_F Offline
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B_F
Joined: Nov 2006
Posts: 7,228
Cincinnati, OH
Originally Posted By: MS Kaybee
You can report $120K in July and $50K in October (you will have to add a suffix or prefix to the loan number for October) or just report $220K in October.


Kaybee, I respect your opinion, but I am confused. Why would it be $50K in October? New money seems to be an additional $100K, so why report only half?

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#1473137 - 11/29/10 03:12 PM Re: How to Report B_F
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Because I was not able to add on the day I responded? You are right, it would be $100,000 for the new money if you reported both loans, old money and new money.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1473166 - 11/29/10 04:11 PM Re: How to Report Kathleen O. Blanchard
B_F Offline
Power Poster
B_F
Joined: Nov 2006
Posts: 7,228
Cincinnati, OH
Thank you! I feel better now. I was going crazy trying to figure out what I'd missed!

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