What documentation would you suggest to prove a community development loan with the purpose of revitalization/stabilization in a moderate- income area? We are financing the purchase and construction of a mixed use development with upper income housing, retail and commercial space. The housing units have been completed but our loan will finance the finish out of the retail/commercial space. Development has TIF credits that our borrower will receive.
What is required in a large bank CRA public file?
Can a loan that is HMDA reportable also be classified as Community Development? (ie: individual business loans on single family residential property in a low/mod area?)
I have a question that involves CRA Reporting for community development loans. If we have mortgage loans that are made to LMI borrowers or are in LMI areas, can we include these as community development loans on our CRA report? They are also included on our HMDA report. I know we get credit for these, but my question is whether we should include them on the CRA report to the FDIC as community development loans.
Have you ever gone back and looked at a law or regulation when it was just adopted and then compared it to today's version? Take CRA for example.
The three banking agencies, OCC, FDIC and the FRB, have issued final revisions to the CRA regulation. The changes take effect on September 1, 2005.
There is no better indicator of how HMDA data will be used than the ideas expressed by members of the Federal Reserve Board's Consumer Advisory Council ("CAC").
The mountain may be moving just a little bit. The three bank regulatory agencies (yes, even the Federal Reserve Board) have published proposed revisions to the CRA regulations.
From the first CRA regulations in the late 1970's to recent years, the bank regulatory agencies have acted together, issuing uniform CRA regulations, guidelines and examination procedures.