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#1525732 - 03/23/11 02:40 PM Automobile loan breakout on Call Report
hatman Offline
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Joined: Nov 2009
Posts: 77
Are the new items concerning automobile loans on the Call Report driven by purpose or collateral? Would you list an unsecured loan whose proceeds are used to purchase a car?

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Lending Compliance
#1525762 - 03/23/11 02:52 PM Re: Automobile loan breakout on Call Report hatman
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
I believe they are driven by purpose. If I understand the priority classification, they fall after loans secured by real estate, those driven by borrower (e.g., depository institutions, foreign governments, etc.), and commercial business.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1525773 - 03/23/11 03:06 PM Re: Automobile loan breakout on Call Report Doug Hendrickson
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
It depends. See instructions:

6.c Automobile loans. Report (on the FFIEC 041, in column B; on the FFIEC 031, in columns A and B, as appropriate) all consumer loans arising from retail sales of passenger cars and other vehicles such as minivans, vans, sport-utility vehicles, pickup trucks, and similar light trucks for personal use.

Exclude from automobile loans:

(1) Consumer loans for purchases of, or otherwise secured by, motorcycles, recreational vehicles, golf carts, boats, and airplanes (report in Schedule RC-C, part I, item 6.d).
(2) Personal cash loans secured by automobiles already paid for (report in Schedule RC-C, part I, item 6.d).
(3) Vehicle flooring or floor-plan loans (report in Schedule RC-C, part I, item 4).
(4) Loans to finance purchases of passenger cars and other vehicles for commercial, industrial, state or local government, or other nonpersonal nonagricultural use (report in Schedule RC-C, part I, item 4, item 8, or item 9, as appropriate).
(5) Loans to finance vehicle fleet sales (report in Schedule RC-C, part I, item 4).
(6) Loans to farmers for purchases of passenger cars and other vehicles used in association with the maintenance or operations of the farm, and loans for purchases of farm equipment (report in Schedule RC-C, part I, item 3).
(7) Consumer automobile lease financing receivables (report in Schedule RC-C, part I, item 10.a).

All loans to individuals for household, family, and other personal expenditures (i.e., consumer loans) originated or purchased before April 1, 2011, that are collateralized by automobiles, regardless of the purpose of the loan, may be classified as automobile loans for purposes of this schedule and other schedules in which information on automobile loans is to be reported.

For consumer loans originated or purchased on or after April 1, 2011, banks should exclude from automobile loans any personal cash loans secured by automobiles already paid for and consumer loans where some of the proceeds are used to purchase an automobile and the remainder of the proceeds are used for other purposes (report in Schedule RC-C, part I, item 6.d).
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1526006 - 03/23/11 06:46 PM Re: Automobile loan breakout on Call Report Kathleen O. Blanchard
hatman Offline
Member
Joined: Nov 2009
Posts: 77
I just received a response from the FDIC Call Report Division. He said the item is collateral driven, not purpose driven. He said an unsecured loan whose proceeds are used to purchase a car would not be listed.

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#1526449 - 03/24/11 03:31 PM Re: Automobile loan breakout on Call Report hatman
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
For going forward, true. But for what is on your books now, take a look at the instructions for pre 4/1/2011 loans.

"All loans to individuals for household, family, and other personal expenditures (i.e., consumer loans) originated or purchased before April 1, 2011, that are collateralized by automobiles, regardless of the purpose of the loan, may be classified as automobile loans for purposes of this schedule and other schedules in which information on automobile loans is to be reported."
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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