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#2111445 - 12/19/16 09:33 PM PURCHASED LOANS
compliance75 Offline
100 Club
Joined: Oct 2016
Posts: 105
I am new at CRA....

Our Bank wants to purchase some residential LMI income/geographies borrowers loans to help our CRA portfolio. The loans are residential, so they will end up in our HMDA LAR. I understand that if a loan is HMDA it cannot be CRA?
Can these loans be considered for investment CRA test purposes?

Any help on what type of credit does a Bank can receive from residential LMI loans?

Thank you.

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#2111460 - 12/20/16 01:00 PM Re: PURCHASED LOANS compliance75
Tennismom Offline
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Tennismom
Joined: Jan 2004
Posts: 778
From the Q and A in the FDIC Compliance Examination Manual https://www.fdic.gov/regulations/compliance/manual/11/XI-11.1.pdf

§ __.23(b) – 2: If home mortgage loans to low- and moderate-income borrowers have been considered under an institution’s lending test, may the institution that originated or purchased them also receive consideration under the investment test if it subsequently purchases mortgage-backed securities that are primarily or exclusively backed by such loans?
A2. No. Because the institution received lending test consideration for the loans that underlie the securities, the institution may not also receive consideration under the investment test for its purchase of the securities. Of course, an institution may receive investment test consideration for purchases of mortgage-backed securities that are backed by loans to low- and moderate-income individuals as long as the securities are not backed primarily or exclusively by loans that the same institution originated or purchased.

I hope this addressed your question.

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#2111679 - 12/21/16 02:49 PM Re: PURCHASED LOANS compliance75
compliance75 Offline
100 Club
Joined: Oct 2016
Posts: 105
Yes, thank you

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