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#1280765 - 11/04/09 07:59 PM Participation lending w/multiple properties
diputs
Unregistered

If we have a qualified community development lending activity of which our bank has a participating portion with other banks and,
The activity consists of multiple properties/facilities located in various locations, some in and some out of our bank’s assessment area…

How do I report on the communities that this lending activity affects? Do I show the corporate location? I’m thinking not… Generally, I attempt to identify any government zoning along with any other LMI designations, etc… to help support the CD benefits.
However, with multiple locations this seems to be quite difficult.

Any suggestions?

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CRA
#1288981 - 11/18/09 06:34 PM Re: Participation lending w/multiple properties
diputs
Unregistered

Bump
???

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#1289239 - 11/18/09 09:11 PM Re: Participation lending w/multiple properties
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,139
Connecticut
You don't report the location of CD activities ironically. The data is collected and compiled by the FFIEC without the location information. However, location is important when the examiners arrive and determine if you have adequate CD lending inside your AA.

You provide far too little information to give you much advice other than to make certain that most if not all your CD lending is located in your AA. Normally CD lending inside your AA counts toward satisfactory performance and outside counts only toward outstanding performance.
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