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#1025165 - 08/21/08 04:47 PM CRA--difference of opinion on renewals
GSR Offline
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Okay---when I read this paragraph:
d. Renewals vs. refinancings. Institutions are permitted to collect data on both refinancings and renewals of loans. So no matter how the loan is renewed or refinanced (that is, whether or not it involves the taking of a new note), the transaction is treated as an origination. However, when reporting small business loan and small farm loan data, the institution is permitted to report only one origination (including a renewal or refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted. The key is to program the institution’s loan system to be able to handle properly the automated tracking and reporting of these small business and small farm loan renewals.

it begs the question---if a renewal is only completed through an amendment/extention agreement NOT a new note would that still be CRA? Make the following assumptions: Yes, all renewals are re-underwritten and credit reviewed, yes it qualifies as a small business CRA loan in both years-- the year it was originated and the next calendar year of renewal.

If you can point me to citations or guidance that would be MOST appreciated.

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#1025611 - 08/21/08 08:45 PM Re: CRA--difference of opinion on renewals GSR
CRAatBOK Offline

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Further South than I wanna be.
Yes, you do NOT have to have a new note to report it (that is only HMDA).
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#1025635 - 08/21/08 09:04 PM Re: CRA--difference of opinion on renewals CRAatBOK
Mrs. Rizzo Offline
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I will look to see what shows on the new note report. If a renewal is done and the maturity date is extended and it shows up on the new note report then I report it for CRA, if qualified.
I believe there are examples in the CRA guide on the FFIEC's website.
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#1025638 - 08/21/08 09:07 PM Re: CRA--difference of opinion on renewals Mrs. Rizzo
Mrs. Rizzo Offline
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Page 11-12
Refinances and Renewals
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#1025646 - 08/21/08 09:31 PM Re: CRA--difference of opinion on renewals Mrs. Rizzo
GSR Offline
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Posts: 59
I pulled out the pages and they do not answer my question unless I am missing it. The language in the guidance addresses renewal with new money only---it is rare in our bank to have a renewal with new money. We simply make pretty much every loan mature in 12 months-review and reunderwrite it before we renew it as we are a commercial bank not retail/consumer.
I need to find something that says--yes a renewal (without a new note) would count so long as it continued to meet the Sm Biz requirements from one year to the next.
Bob's Brakes origined loan of $250k in 2006, gross revenue of $900k, Bob's brakes renews in 2007 no new money, no new note and gross revenues are now $990k...reported in 2006 as CRA Sm Biz and again in 2007 as CRA Sm Biz---correct? Where does it say that?

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#1025708 - 08/21/08 10:44 PM Re: CRA--difference of opinion on renewals GSR
Mrs. Rizzo Offline
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The Q and A .42(a)-5 says that a "renewal" refers to an extension of the term of the loan.
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#1025713 - 08/21/08 10:51 PM Re: CRA--difference of opinion on renewals Mrs. Rizzo
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http://www.ffiec.gov/cra/pdf/qa01.pdf

Look at 42-4 and 42-5 and see if that is the answer you are looking for.
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#1028517 - 08/26/08 06:55 PM Re: CRA--difference of opinion on renewals Mrs. Rizzo
GSR Offline
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yes, thank you!

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