§__.12(j) Home Equity Loans as Consumer Loans
§__.12(j) – 1 Q: Are home equity loans considered “consumer loans”? A1. Home equity loans made for purposes other than home purchase, home improvement, or refinancing home purchase or home improvement loans are consumer loans if they are extended to one or more individuals for household, family, or other personal expenditures. Source: Interagency Questions & Answers Regarding…
§__.12(j) Home Equity Lines of Credit as Consumer Loans
§__.12(j) – 2 Q: May a home equity line of credit be considered a “consumer loan” even if part of the line is for home improvement purposes? A2. If the predominant purpose of the line is home improvement, the line may only be reported under HMDA and may not be considered a consumer loan. However, the full…
§__.12(j) Reporting Loans with Multiple Purposes
§__.12(j) – 3 Q: How should an institution collect or report information for loans the proceeds of which will be used for multiple purposes? A3. If an institution makes a single loan or provides a line of credit to a customer to be used for both consumer and small business purposes, consistent with the instructions for the…
§__.12(l) Home Mortgage Loan v. Home Purchase Loan
§__.12(l) – 1 Q: Does the term “home mortgage loan” include loans other than “home purchase loan”? A1. Yes. “Home mortgage loan” includes “home improvement loan,” “home purchase loan,” and “refinancing,” as defined in the HMDA regulation, Regulation C, 12 CFR part 1003. This definition also includes multifamily (five-or-more families) dwelling loans, and loans for the purchase of…
§__.12(l) CRA Consideration for Mortgage Brokerage Activities
§__.12(l) – 2 Q: Some financial institutions broker home mortgage loans. They typically take the borrower’s application and perform other settlement services; however, they do not make the credit decision. The broker institutions may also initially fund these mortgage loans, then immediately assign them to another lender. Because the broker institution does not make the credit…
§__.12(m) Income Level Data
§__.12(m) – 1 Q: Where do institutions find income level data for geographies and individuals? A1. The median family income (MFI) levels for geographies, i.e., census tracts, are calculated using income data from the U.S. Census Bureau’s American Community Survey (ACS) and geographic definitions from the Office of Management and Budget (OMB), and are updated approximately every five…
§__.12(n) Narrow Product Line Clarification for Limited Purpose Institution
§__.12(n) – 1 Q: What constitutes a “narrow product line” in the definition of “limited purpose institution”? A1. An institution offers a narrow product line by limiting its lending activities to a product line other than a traditional retail product line required to be evaluated under the lending test (i.e., home mortgage, small business, and small…
§__.12(n) Factors Affecting Wholesale/Limited Purpose Institution Designation
§__.12(n) – 2 Q: What factors will the Agencies consider to determine whether an institution that, if limited purpose, makes loans outside a narrow product line, or, if wholesale, engages in retail lending, will lose its limited purpose or wholesale designation because of too much other lending? A2. Wholesale institutions may engage in some retail lending without…
§__.12(n) Niche Institutions
§__.12(n) – 3 Q: Do “niche institutions” qualify as limited purpose (or wholesale) institutions? A3. Generally, no. Institutions that are in the business of lending to the public, but specialize in certain types of retail loans (for example, home mortgage or small business loans) to certain types of borrowers (for example, to high-end income level customers or…
§__.12(t) CRA Investment Authority
§__.12(t) – 1 Q: Does the CRA regulation provide authority for institutions to make investments? A1. No. The CRA regulation does not provide authority for institutions to make investments that are not otherwise allowed by Federal law. Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016