§__.42(b)(2) CRA Data Reporting on Loan Participations
§__.42(b)(2) – 4 Q: When an institution purchase a participation in a community development loan, which amount should the institution report – the entire amount of the credit originated by the lead lender or the amount of the participation purchased? A4. The institution reports only the amount of the participation purchased as a community development loan. However,…
§__.42(b)(2) CRA Data Reporting on Community Development Loan Refinances and Renewals
§__.42(b)(2) – 5 Q: Should institutions collect and report data about community development loans that are refinanced or renewed? A5. Yes. Institutions should collect information about community development loans that they refinance or renew as loan originations. Community development loan refinancings and renewals are subject to the reporting limitations that apply to refinancings and renewals of small business…
§__.42(b)(3) CRA Data Collection for Mortgage Loans for non-HMDA Reporters
§__.42(b)(3) – 1 Q: Must institutions that are not required to collect home mortgage loan data by the HMDA collect home mortgage loan data for purposes of the CRA? A1. No. If an institution is not required to collect home mortgage loan data by the HMDA, the institution need not collect home mortgage loan data under the…
§__.42(c)(1) CRA Data Requirements for Consumer Loans
§__.42(c)(1) – 1 Q: What are the data requirements regarding consumer loans? A1. There are no data reporting requirements for consumer loans. Institutions may, however, opt to collect and maintain data on consumer loans. If an institution chooses to collect information on consumer loans, it may collect data for one or more of the following categories of…
§__.42(c)(1)(iv) CRA Reportable Income Requirements for Consumer Loans
§__.42(c)(1)(iv) – 1 Q: If an institution does not consider income when making an underwriting decision in connection with a consumer loan, must it collect income information? A1. No. Further, if the institution routinely collects, but does not verify, a borrower’s income when making a credit decision, it need not verify the income for purposes of data…
§__.42(c)(1)(iv) Reportable Income on Employee Consumer Loans
§__.42(c)(1)(iv) – 2 Q: May an institution list “0” in the income field on consumer loans made to employees when collecting data for CRA purposes as the institution would be permitted to do under HMDA? A2. Yes. Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016
§__.42(c)(1)(iv) Reporting Gross Annual Income on Consumer Loans
§__.42(c)(1)(iv) – 3 Q: When collecting the gross annual income of consumer borrowers, do institutions collect the gross annual income or the adjusted gross annual income of the borrowers? A3. Institutions collect the gross annual income, rather than the adjusted gross annual income, of consumer borrowers. The purpose of income data collection in connection with consumer loans…
§__.42(c)(1)(iv) Reportable Income on Consumer Loans with Multiple Borrowers
§__.42(c)(1)(iv) – 4 Q: Whose income does an institution collect when a consumer loan is made to more than one borrower? A4. An institution that chooses to collect and maintain information on consumer loans collects the gross annual income of all primary obligors for consumer loans, to the extent that the institution considered the income of the…
§__.42(c)(2) CRA Data Collection on Commercial Loans Secured by Residential Real Estate
§__.42(c)(2) – 1 Q: Call Report Schedule RC-C, Part II does not allow institutions to report loans for commercial and industrial purposes that are secured by residential real estate, unless the security interest in the nonfarm residential real estate is taken only as an abundance of caution. (See Q&As §__.12(v) – 3) Loans extended to small…
§__.42(c)(2) CRA Data Collection on Loan Commitments and Letters of Credit
§__.42(c)(2) – 2 Q: Must an institution collect data on loan commitments and letters of credit? A2. No. Institutions are not required to collect data on loan commitments and letters of credit. Institutions may, however, provide for examiner consideration information on letters of credit and commitments. Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016