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CRA Reporting for Community Development Loans

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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.

No. One primary rule of CRA data reporting is that a loan may only be used once. If a regulation such as HMDA requires that it be reported, then that is where the loan must go. The income level reported on the LAR will present the fact that the loan is to a low-income borrower.

That being said, it never hurts to have a presentation ready for the examiner to show how you have made an impact on a low- or moderate-income community. Many CRA managers do this to present the lending and investment activities in a CRA context just to be sure the examiner understands where the money and effort went.

First published on 2/6/06

First published on 02/06/2006

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