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#1481826 - 12/16/10 07:42 PM CRA loan if not business purpose?
JustGottaKnow Offline
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Joined: Aug 2008
Posts: 77
I have had a few deals where the loan is in the name of the business and the collateral is a blanket lien. The call code seems to be correct as 04A0; however, the actual purpose of the loan is not a business purpose....payoff personal tax liability, refinance mortgage on personal residence. Are these loans still CRA reportable?

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CRA
#1481834 - 12/16/10 07:48 PM Re: CRA loan if not business purpose? JustGottaKnow
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Are you taking a lien on the residence? If so, your loan is reportable on HMDA and not on CRA.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
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#1481847 - 12/16/10 08:00 PM Re: CRA loan if not business purpose? Princess Romeo
JustGottaKnow Offline
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Joined: Aug 2008
Posts: 77
No lien on the residence, only a blanket. Are they CRA?

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#1481878 - 12/16/10 08:38 PM Re: CRA loan if not business purpose? JustGottaKnow
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
It sounds like the loan does not have the correct Call Code. Here are the Call Code instructions for RC-C Line 04a

Commercial and industrial loans. Report loans for commercial and industrial purposes to sole proprietorships, partnerships, corporations, and other business enterprises, whether secured (other than those that meet the definition of a “loan secured by real estate”) or unsecured, single-payment or installment.

It sounds like the loan meets the definition for code 9b

9 All other loans include all loans and discounts (other than loans to nondepository financial institutions and loans for purchasing or carrying securities) that cannot properly be reported in one of the preceding items in Schedule RC-C, part I,

9.b.(2) All other loans. Report (on the FFIEC 041, in column A; on the FFIEC 031, in column B) all other loans (on the FFIEC 031, in domestic offices) as described above.

http://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_201009_i.pdf
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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