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#2139497 - 07/25/17 09:31 PM IN vs OUT
compliance75 Offline
100 Club
Joined: Oct 2016
Posts: 105
What are the rules to determine whether a loan is inside or outside the AA, by the borrower's address or by the collateral? Or is it by primary use of funds? thanks

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CRA
#2139558 - 07/26/17 03:03 PM Re: IN vs OUT compliance75
Nickel0207 Offline
Junior Member
Joined: Jul 2017
Posts: 30
Again 2015 guide:

https://www.ffiec.gov/cra/pdf/2015_CRA_Guide.pdf

If you CTRL+F and search "loan location" a good number of items will pull-up

• A small business or small farm
loan is located in the geography
where the main business facility
or farm is located or where the
loan proceeds otherwise will
be applied,



SECTION __.42(a)(3) – 1: Which
location should an institution
record if a small business loan’s
proceeds are used in a variety of
locations?
A1. The institution should record the
loan location by either the location
of the small business borrower’s
headquarters or the location where
the greatest portion of the proceeds
are applied, as ind

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#2139562 - 07/26/17 03:12 PM Re: IN vs OUT compliance75
compliance75 Offline
100 Club
Joined: Oct 2016
Posts: 105
Thanks

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#2140136 - 07/28/17 11:53 PM Re: IN vs OUT compliance75
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
By the address reported on the HMDA/LAR for mortgages.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

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