§__.12(u)(2) Institution Asset Size Threshold Adjustment
§__.12(u)(2) – 1 Q: How often will the asset size thresholds for small institutions and intermediate small institutions be changed, and how will these adjustments be communicated? A1. The asset size thresholds for “small institutions” and “intermediate small institutions” will be adjusted annually based on changes to the Consumer Price Index. More specifically, the dollar thresholds will be…
§__.12(v) Loans to Nonprofits Classification
§__.12(v) – 1 Q: Are loans to nonprofit organizations considered small business loans or are they considered community development loans? A1. To be considered a small business loan, a loan must meet the definition of “loans to small businesses” in the instructions in the Call Report. In general, a loan to a nonprofit organization, for business or…
§__.12(v) Small Business Loans Secured by Commercial Real Estate
§__.12(v) – 2 Q: Are loans secured by commercial real estate considered small business loans? A2. Yes, depending on their principal amount. Small business loans include loans secured by “nonfarm nonresidential properties,” as defined in the Call Report, in amounts of $1 million or less. Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016
§__.12(v) Small Business Loans Secured by Residential Real Estate
§__.12(v) – 3 Q: Are loans secured by nonfarm residential real estate to finance small businesses “small business loans”? A3. Typically not. Loans secured by nonfarm residential real estate that are used to finance small businesses are not included as “small business” loans for Call Report purposes unless the security interest in the nonfarm residential real estate is…
§__.12(t) Credit Cards as Small Business Loans
§__.12(v) – 4 Q: Are credit cards issued to small businesses considered “small business loans”? A4. Credit cards issued to a small business or to individuals to be used, with the institution’s knowledge, as business accounts are small business loans if they meet the definitional requirements in the Call Report instructions. Source: Interagency Questions & Answers Regarding Community…
§__.12(x) Wholesale Institution Factors
§__.12(x) – 1 Q: What factors will the Agencies consider in determine whether an institution is in the business of extending home mortgage, small business, small farm, or consumer loans to retail customers? A1. The Agencies will consider whether the institution holds itself out to the retail public as providing such loans. the institution’s revenues from extending…
§__.21(a) Application of Performance Criteria During CRA Examination
§__.21(a) – 1 Q: How will examiners apply the performance criteria? A1. Examiners will apply the performance criteria reasonably and fairly, in accord with the regulations, the examination procedures, and this guidance. In doing so, examiners will disregard efforts by an institution to manipulate business operations or present information in an artificial light that does not…
§__.21(a) Community Development Activity Examination Weight
§__.21(a) – 2 Q: Are all community development activities weighted equally by examiners? A2. No. Examiners will consider the responsiveness to credit and community development needs, as well as the innovativeness and complexity, if applicable, of an institution’s community development lending, qualified investments, and community development services. These criteria include consideration of the degree to which they…
§__.21(a) Evaluation of Responsiveness
§__.21(a) – 3 Q: “Responsiveness” to credit and community development needs is either a criterion or otherwise a consideration in all of the performance tests. How do examiners evaluate whether a financial institution has been “responsive” to credit and community development needs? A3. There are three important factors that examiners consider when evaluating responsiveness: quantity, quality, and…
§__.21(a) Innovativeness Definition
§__.21(a) – 4 Q: What is meant by “innovativeness”? A4. “Innovativeness” is one of several qualitative considerations under the lending, investment, and service tests. The community development test for wholesale and limited purpose institutions similarly considers “innovative” loans, investments, and services in the evaluation of performance. Under the CRA regulations, all innovative practices or activities will be…