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#2096069 - 08/30/16 05:09 PM CRA Address-Buying An Interest In A Business
Breeco Offline
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Breeco
Joined: Aug 2014
Posts: 95
Nebraska
We have an individual borrower that is buying 50% interest share into to a real estate company that owns a single property. The LLC owned the real estate property prior to our borrower coming in to the picture.

(A) Would one say the funds are being used to invest in the LLC and use the LLC's address as the CRA reportable address; or

(B) Would one say since the person is investing in a company that owns it's real estate as an asset; the CRA address used would be the same as the real estate asset the LLC owns?

The LLCs main office is not the same address as the real estate it owns.

Clear as mud......

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#2096083 - 08/30/16 05:45 PM Re: CRA Address-Buying An Interest In A Business Breeco
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
Who is the borrower, the individual? What is your borrower's address on the bank's books and records? Where is that customer's main "office"?

The second question is where are the proceeds "used"? The proceeds seem to be going to the LLC. The proceeds address would be the second alternative over the borrower's main address.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2096092 - 08/30/16 06:03 PM Re: CRA Address-Buying An Interest In A Business Kathleen O. Blanchard
Breeco Offline
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Breeco
Joined: Aug 2014
Posts: 95
Nebraska
-The bank's borrower is an individual person.
-The borrower's address is different than the LLC's address or the real estates address.
-The LLC is not the bank's borrower.
-The proceeds were given to the LLC to buy 50% ownership of the the LLC.

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#2096155 - 08/30/16 08:06 PM Re: CRA Address-Buying An Interest In A Business Breeco
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You report your borrower's main business address or the use of proceeds address., which would be the LLC address.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2097157 - 09/07/16 01:45 PM Re: CRA Address-Buying An Interest In A Business Kathleen O. Blanchard
Breeco Offline
Member
Breeco
Joined: Aug 2014
Posts: 95
Nebraska
I agree, but the business unit and CRA Dept overruled me for the real estate address.

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#2097356 - 09/07/16 11:13 PM Re: CRA Address-Buying An Interest In A Business Breeco
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Well, I guess they cannot read instructions. smile
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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