Skip to content
BOL Conferences
Thread Options
#1537197 - 04/19/11 12:56 PM CRA AA Question
sway Offline
100 Club
Joined: Feb 2011
Posts: 128
Our 2009 examination's scope included only residential mortgage and business purpose loans. Small farm loans were not evaluated. Also, not evaluated was our car loans. When reassessing our assessment area should I take into account car loans or should I look at our assessment area as the examiner did previously?

Return to Top
CRA
#1537200 - 04/19/11 01:00 PM Re: CRA AA Question sway
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You should review the Call Report and see what percentage of the portfolio each of those categories makes up. The examiners will base the rating on those that are the primary products, leaving out that are only a small %, unless you specifically request other portfolios be included.

If you feel the loans like car loans are key to your banks serving the community and will enhance the performance measurement, then you can request that the portfolio be included and consider it for the assessment area.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top