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#1967078 - 10/06/14 12:00 PM Comm Development Loan & AA
CompMan1 Offline
Junior Member
Joined: Jan 2013
Posts: 36
We report CDLs to our board quarterly, both inside and outside our AA. We have a CDL made about 2 years ago (still on our books) then outside our AA. After a recent expansion of our AA, it now falls within our AA. For our next board report, should we show it as being inside our current AA or continue to show it as outside since that's where it was when it was made?

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CRA
#1967180 - 10/06/14 05:07 PM Re: Comm Development Loan & AA CompMan1
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
What you report to the board is totally up to you. But the loan is where it is and that is inside your AA.
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#1967187 - 10/06/14 05:15 PM Re: Comm Development Loan & AA CompMan1
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
If has been included in an exam, I would for the next exam (if it is still on the books at that time)include the information that this loan was not originally in the AA but is still on the books and is now in and benefiting the AA.

If the loan has not been reviewed in an exam yet, your AA is what you say it is for the exam. The performance context will address changes to the AA over time and anywhere that impacts performance (you are low in certain areas because they were added to the AA 3 months before the exam, for example).
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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