CRA Reporting: Loan Assumptions

Is an assumption CRA reportable?

Did anyone have any thoughts on this?

What is reported under CRA are small business and small farm loans that are originated, refinanced, or renewed as defined in the Regulation.

However, for HMDA purposes:

Regulation C provides two narrow exceptions to the requirement that an “extension of credit” involve a new debt obligation. The exceptions are designed to capture transactions that are substantially similar to new debt obligations and should be treated as such.
1. Assumptions. Assumptions are extensions of credit under Regulation C. A loan assumption is a transaction in which a financial institution enters into a written agreement accepting a new borrower in place of an existing borrower as the obligor on an existing debt obligation. Regulation C clarifies that assumptions include successor-in-interest transactions in which an individual succeeds the prior owner as the property owner and then assumes the existing debt secured by the property. Assumptions are extensions of credit even if the new borrower merely assumes the existing debt obligation and no new debtCRA covers loans you originate, refinance or renew.