Small Business/Farm/CD Lending

Our holding company operates a Bank regulated by the OCC and a Thrift regulated by the OTS. My question is: Can the Bank report the Thrift's small business and small farm loans, since the Thrift is examined under the small savings procedures and doesn't have to report those loans, but still retain the Thrift's community development loans for CRA credit for the Thrift's CRA Exam?

In other words if the Bank reports the Thrift's small business and small farm loans does it also have to report the community development loans on the Bank side?

You have two different charters regulated by two different agencies. Each entity must comply with the regulations required by the agency that regulates it.

The OCC bank did not originate the loans and therefore cannot take credit for loans originated by another institution.

If you purchase participation's in the loans you could report what the OCC bank purchased.

Each entity reports its own Community Development activities. One institution cannot take credit for what another one does. Same as loans

Thanks for your help Don!