§__.22(a)(2) CRA Evaluation of Loan Commitments
§__.22(a)(2) – 1 Q: How are lending commitments (such as letters of credit) evaluated under the regulation? A1. The Agencies consider lending commitments (such as letters of credit) only at the option of the institution, regardless of examination type. Commitments must be legally binding between an institution and a borrower in order to be considered Information about lending…
§__.22(a)(2) Review of Loan Application Data
§__.22(a)(2) – 2 Q: Will examiners review application data as part of the lending test? A2. Application activity is not a performance criterion of the lending test. However, examiners may consider this information in the performance context analysis because this information may give examiners insight on, for example, the demand for loans. Source: Interagency Questions & Answers Regarding…
§__.22(a)(2) CRA Consideration for Purchased Loan Modifications and Extensions
§__.22(a)(2) – 3 Q: May a financial institutions receive consideration under CRA for home mortgage loan modification, extension, and consolidation agreements (MECA), in which it obtains home mortgage loans from other institutions without actually purchasing or refinancing the home mortgage loans, as those terms have been interpreted under CRA and HMDA, as implemented by 12 CFR…
§__.22(a)(2) Other Loan Data Examples
§__.22(a)(2) – 4 Q: In addition to MECAs (Modifications, Extensions, and Consolidation Agreements), what are other examples of “other loan data”? A4. Other loan data include, for example, loans funded for sale to the secondary markets that an institution has not reported under HMDA; unfunded loan commitments and letters of credit; commercial and consumer leases; loans secured…
§__.22(a)(2) CRA Consideration for Fully Guaranteed Loans
§__.22(a)(2) – 5 Q: Do institutions receive consideration for originating or purchasing loans that are fully guaranteed? A5. Yes. For all examination types, examiners evaluate an institution’s record of helping to meet the credit needs of its assessment area(s) through the origination or purchase of specified types of loans. Examiners do not take into account whether or…
§__.22(a)(2) CRA Consideration for Loan Participation Purchases
§__.22(a)(2) – 6 Q: Do institutions receive consideration for purchasing loan participations? A6. Yes. Examiners will consider the amount of loan participations purchased when evaluating an institution’s record of helping to meet the credit needs of its assessment area(s) through the origination or purchase of specified types of loans, regardless of examination type. As with other loan…
§__.22(a)(2) Small Business Refinances Secured by Residential Real Estate
§__.22(a)(2) – 7 Q: How are refinancings of small business loans, which are secured by a one-to-four family residence and that have been reported under HMDA as a refinancing, evaluated under CRA? A7. A loan of $1 million or less with a business purpose that is secured by a one- to-four family residence is considered a small…
§__.22(b)(1) CRA Evaluation of Affiliate Lending Referrals
§__.22(b)(1) – 1 Q: How will the Agencies apply the lending activity criterion to discourage an institution from originating loans that are view favorably under CRA in the institution itself and referring other loans, which are not viewed as favorably, for origination by an affiliate? A1. Examiners will review closely institutions with (1) a small number and…
§__.22(b)(2) & (3) Geographic Distribution and Borrower Characteristics of Loans
§__.22(b)(2) & (3) – 1 Q: How do the geographic distribution of loans and the distribution of lending by borrower characteristics interact in the lending test applicable to either large or small institutions? A1. Examiners generally will consider both the distribution of an institution’s loans among geographies of different income levels, and among borrowers of different income levels and…
§__.22(b)(2) & (3) Lending in All Portions of Assessment Area
§__.22(b)(2) & (3) – 2 Q: Must an institution lend to all portions of its assessment area? A2. The term “assessment area” describes the geographic area within which the agencies assess how well an institution, regardless of examination type, has met the specific performance tests and standards in the rule. The Agencies do not expect that simply…