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#1507951 - 02/10/11 03:13 PM Small Business Loan?
BNKO Offline
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Posts: 213
Is a loan in the amount of $1 million or less that is secured by MULTI-FAMILY property considered a small business loan for CRA reporting purposes?

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CRA
#1507964 - 02/10/11 03:22 PM Re: Small Business Loan? BNKO
RR Becca Offline
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RR Becca
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
No, it's a HMDA loan. It may also be a CD loan depending on the purpose, collateral, and borrower.
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You call it ADD. I call it multi-tasking.

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#1507986 - 02/10/11 03:38 PM Re: Small Business Loan? RR Becca
BNKO Offline
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Posts: 213
Thanks!

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#1507988 - 02/10/11 03:40 PM Re: Small Business Loan? BNKO
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Well,it is HMDA if it meets a HMDA purpose (purchase, home improvement, refinance).

If the mortgage is just a collateral mortgage for a non-HMDA purpose and the lien is not securing > 50% of the loan or is abundance of caution, it can be small business.
Last edited by Kathleen B; 02/10/11 03:41 PM.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1508000 - 02/10/11 03:48 PM Re: Small Business Loan? Kathleen O. Blanchard
RR Becca Offline
Power Poster
RR Becca
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
^^^ true. I tend to forget about those <50% liens.
_________________________
You call it ADD. I call it multi-tasking.

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#1508002 - 02/10/11 03:51 PM Re: Small Business Loan? RR Becca
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
They don't come off often but if there is other collateral it is possible. So, just for the sake of accuracy and education I mentioned it.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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