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#1708721 - 06/08/12 08:59 PM Letters of Credit
scb2011 Offline
Gold Star
Joined: Mar 2011
Posts: 258
TN
Can letters of credit count for CRA for intermediate small banks if they are within our assessment area?

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CRA
#1708756 - 06/08/12 10:53 PM Re: Letters of Credit scb2011
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You would present them in category 9 other if you have enough youu want to point them out. If you feel that they qualify for community devellipment you would write them up and present in that category.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1715483 - 06/28/12 06:00 PM Re: Letters of Credit scb2011
rocky Offline
Member
Joined: Jul 2009
Posts: 92
Letters of credit will not get you community development loan credit. We (ISB) had gone through an exam with the FRB where we presented a letter of credit in support of affordable housing to LMI households and it got rejected.

Here's what the examiner commented: "letters of credit do not qualify as CD loans, however, special mention can be given in PE." Not sure how it will be mentioned in our PE. We have yet to received our PE...

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#1715690 - 06/29/12 02:15 AM Re: Letters of Credit rocky
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Originally Posted By: rocky
Letters of credit will not get you community development loan credit. We (ISB) had gone through an exam with the FRB where we presented a letter of credit in support of affordable housing to LMI households and it got rejected.

Here's what the examiner commented: "letters of credit do not qualify as CD loans, however, special mention can be given in PE." Not sure how it will be mentioned in our PE. We have yet to received our PE...

Bear in mind that this varies from exam team to exam team. I would still write it up and explain in great detail why the project could not happen without the LC. Banks have received CD credit for LCs.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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