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#1800494 - 04/02/13 04:44 PM CRA Products
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,315
We are formalizing our loss mitigation policies, programs, etc. for the new mortgage servicing laws. Will loan programs specifically established to provide long-term debt relief and avoid foreclosure through restructures/modifications qualify as a product that is responsive to the needs of the bank's AA?

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#1800499 - 04/02/13 04:51 PM Re: CRA Products Mel in WA
Reads Regs Offline
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Joined: Nov 2004
Posts: 2,310
Search the March 2010 Interagency Q&As on CRA for the word "foreclosure" and you will find some guidance. http://www.ffiec.gov/cra/pdf/2010-4903.pdf

The following quote is from page 11655.
"Establishing loan programs with the objective of providing affordable, sustainable, long-term relief, for example, through loan refinancings, restructures, or modifications, to homeowners who are facing foreclosure on their primary residences."
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

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#1800503 - 04/02/13 05:01 PM Re: CRA Products Reads Regs
Mel in WA Offline
Diamond Poster
Joined: Mar 2013
Posts: 1,315
That's exactly what I read that made me think we could get credit for these type of programs.

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#1800512 - 04/02/13 05:25 PM Re: CRA Products Mel in WA
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Write it up properly and you will receive credit.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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