§__.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
§__.42(c)(2) CRA Data Collection on Commercial and Consumer Leases
§__.42(c)(2) – 3 Q: Are commercial and consumer leases considered loans for purposes of CRA data collection? A3. Commercial and consumer leases are not considered small business or small farm loans or consumer loans for purposes of the data collection requirements in 12 CFR .42(a) & (c)(1). However, if an institution wishes to collect and maintain data…
§__.42(d) Availability of Affiliate Lending Data for CRA Evaluation
§__.42(d) – 1 Q: If an institution elects to have an affiliate’s home mortgage lending considered in its CRA evaluation, what data must the institution make available to examiners? A1. If the affiliate is a HMDA reporter, the institution must identify those loans reported by its affiliate under 12 CFR part 1003 (Regulation C, implementing HMDA). At…
§__.43(a)(1) Public Comments Received by the Agencies
§__.43(a)(1) – 1 Q: What happens to comments received by the Agencies? A1. Comments received by an Agency will be on file at the Agency for use by examiners. Those comments are also available to the public unless they are exempt from disclosure under the Freedom of Information Act. Source: Interagency Questions & Answers Regarding Community Reinvestment…
§__.43(a)(1) Required Institution Response to Received Public Comments
§__.43(a)(1) – 2 Q: Is an institution required to respond to public comments? A2. No. All institutions should review comments and complaints carefully to determine whether any response or other action is warranted. A small institution subject to the small institution performance standards is specifically evaluated on its record of taking action, if warranted, in response to…
§__.43(a)(2) Inclusion of Institution Response to CRA Public Evaluation in Public File
§__.43(a)(2) – 1 Q: May an institution include a response to its CRA performance evaluation in its public file? A1. Yes. However, the format and content of the evaluation, as transmitted by the supervisory Agency, may not be altered or abridged in any manner. In addition, an institution that received a less than satisfactory rating during it…