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Reporting Consumer Loans on Land

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Question: 
What are the rules for reporting Consumer Loans on Land for CRA purposes? More specifically, would you use the geo info of the consumer or the land being bought or refinanced?
Answer: 

Consumer loans are not reported for CRA purposes. The bank can choose to present them during an examination if they will help to demonstrate that the bank is meeting the credit needs of its community, or may be required during an examination if consumer lending is a primary product of the bank.

The loans would be categorized into the appropriate CRA category and geocoded for either the consumer borrowers address or the location of the loan purchased. Most banks would just use the consumer's address.

The categories for consumer loans are:

04 = Home Equity
05 = Motor Vehicle
06 = Credit Card
07 = Other Secured Consumer Loans
08 = Other Unsecured Consumer Loans
09 = Other Loan Data

First published on BankersOnline.com 5/2/11

First published on 05/02/2011

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