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#1494989 - 01/13/11 08:56 PM Guidance Lines
PennyLane Offline
Member
Joined: Jan 2010
Posts: 71
Orlando, FL
I thought I had read a post in regards to guidance lines and if we had reported the entire approval amount - say $1MM we could not report the individual dispersment amounts. However, I just found an article that states that disbursements can be reported on an individual basis if there are seperate and distinct notes - even if we reported the guidance line already as small business; this would be double dipping??? Confused any clarification on how or if you report your guidance lines is much appreciated.

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CRA
#1495075 - 01/13/11 10:17 PM Re: Guidance Lines PennyLane
bubs63 Offline
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bubs63
Joined: May 2003
Posts: 665
Highland Park IL
The guidance line is not reportable becuase you do not actually have a loan until a draw is done. Then you will have a note under that guidance line. Each note drawn under the Guidance line is reportable.
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Bubs-

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#1495137 - 01/14/11 01:18 AM Re: Guidance Lines PennyLane
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Let me just add that it depends upon how your bank uses the term guidance line. To me a guidance line is an internal approval to speed future requests for a good client. The guidance line is not communicated to the borrower. Actual borrowings are documented with notes.

However, I have seen banks actually communicate and document what they call "guidance lines". Those are sometimes discretionary lines of credit (vs committed lines of credit from an accounting standpoint) or non-revolving lines, where there is a master note and each subsequent draw is a separate note. I do not know why banks call these guidance lines.

If you have a master note that you report you would not report the subsequent draws. If you do not report the master note, report the subsequent notes at each draw. If a discretionary line report the amount of the note.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
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