I have a small business RLOC that was extended multiple times. The last extension decreased the line amount but increased the rate. I have a couple of questions.

1) is it a renewal if the rate has increased given the terms are no longer the same?

2) if the previous loan amount was 150,000 and the new loan amount is 90,000 but there is a balance on the line, what amount do we report?

As long as it has not been renewed already in the same calendar year, you would report the maximum amount available on the line at renewal, in this case $90,000.

Given the above, regarding #1: It is a renewal if you are extending the maturity date. Regarding #2: a balance on the line is not a factor in the reportable amount for renewing a RLOC, it is the credit limit.

So GuitarDude,

Even if the rate goes up, it wouldn't be considered a new loan origination?
Also, the line was renewed (had change in terms documents signed) 4 times previously, within the same year. All were in the amount of 150,000. Then the last and current one was reduced to 90,000. So then what?

Rate changes don't matter for CRA reporting.

For second question, report the first $150,000 for the year and ignore the others and the decrease.

ok, thank you MsKaybee. couldnt understand why the bank reported 75,000 for loan amount on the CRA report. Also just to make it crystal clear, if there were previous change in terms for the loan in the prior years, would this matter? The loan originally started in 2006 at 200,000.

Prior years don't matter.

thank you!

Rule of thumb for same year refi/renewal for CRA:

Same amount, leave the original loan reported

Increase, report the original $ and date, and the new $ with the new date - you will have to differentiate the loan number somehow - you will be reporting 2 loans

or

Increase, just report the second (or final, if more than 1) loan with the new increased total and the date. You will be reporting 1 loan

sorry but one last question for the day.

If the Line of credit was extended / renewed a few times within 1 year, do we report the 1st date?

I always just stick with the first date unless here was a change in amount. Up, I use the new date and amount. Down, I leave the original (within the year) date. I have not had any problem with examiners with this method.

So, where is all this reporting info instructions? I read the FFIEC Guide to Data Collection and reporting and it doesnt spell out any of this..I couldnt find the very intricate instructions anywhere.

Well, they tell you you can report a renewal a second time if there is new money, and report the new money with the second date...or they give an example of reporting once with the total (old and new money). That example uses over a year end, but there is no reason it doesn't work within the calendar year.

Also, if you report the loan and it is renewed for the same amount - all you would be changing is the date. Why bother?

If you renew for a lower amount, you would lose credit for the higher amount you did the first time by using the renewal lower amount...makes no sense. Report the original loan.

If you have an increase, you can follow the option to report the second loan with new money only and adjust your loan number. That is a lot of work if there are more than a handful of loans. By reporting it once with the second date and amount (the increased amount) you get the same $ and only lose 1 loan in the count. If it would cause a radical change in the # of loans, then report the original and the second with new money for the second time around.

When I am dealing with thousands of loans, it is easier to pull my renewal dates and renewal amounts and report once when I have an increase.

makes sense. Again, thank you very much Kathleen.