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#1808048 - 04/25/13 04:49 PM Midterm Increase, Same Maturity, Different Year
GuitarDude Offline
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GuitarDude
Joined: Nov 2004
Posts: 5,925
So Cal
I have been searching and searching and I can't seem to find guidance or an example of my scenario.

I see lots of discussion on CRA LR reporting of increases in the same year but not in different years. So finally, my question:

We have a business LOC that originated in Oct 2012 for $200M and was increased in April 2013 to $300M, with no change to the maturity date. Do we still just report the increase since there was no extension/renewal of the maturity date, or do we report the full $300M since it has not yet been reported at all in 2013? Or do we pick one of those methods and stick to it (consistency)?

Thanks.
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#1808471 - 04/26/13 04:02 PM Re: Midterm Increase, Same Maturity, Different Year GuitarDude
CM-Compliance Offline
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Joined: Oct 2011
Posts: 58
Missouri
I would report the $300M loan this year. It's a new credit this year for the increased amount and since it hasn't been reported, I would use the full LOC.

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#1808476 - 04/26/13 04:08 PM Re: Midterm Increase, Same Maturity, Different Year GuitarDude
bOaty Offline
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Joined: Aug 2006
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Chillin an grillin
GD, I have always reported the increased amount only when there has been no extension of the maturity date and haven't had any issues with that.

If you read page 49 from the Guide to CRA Data Collection and Reporting it tells you to aggregate the amount at the time of the renewal but it does not address what happens if it's not a renewal and just an increase.

I guess what I'm trying to say is I don't know the definitive answer, maybe I have been doing it wrong all these years?
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#1808481 - 04/26/13 04:12 PM Re: Midterm Increase, Same Maturity, Different Year GuitarDude
bOaty Offline
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bOaty
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Chillin an grillin
My logic is that the original amount was not extended again, it was given to the customer at origination. I would only report the newly committed money.
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#1808491 - 04/26/13 04:26 PM Re: Midterm Increase, Same Maturity, Different Year GuitarDude
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Originally Posted By: GuitarDude
I have been searching and searching and I can't seem to find guidance or an example of my scenario.

I see lots of discussion on CRA LR reporting of increases in the same year but not in different years. So finally, my question:

We have a business LOC that originated in Oct 2012 for $200M and was increased in April 2013 to $300M, with no change to the maturity date. Do we still just report the increase since there was no extension/renewal of the maturity date, or do we report the full $300M since it has not yet been reported at all in 2013? Or do we pick one of those methods and stick to it (consistency)?

Thanks.


Is it a new note? Many banks do not handle their reporting loan by loan and if a new note, their system would pick it up at the new amount.

If you did a modification, I would just report the increase.
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#1808792 - 04/26/13 08:55 PM Re: Midterm Increase, Same Maturity, Different Year GuitarDude
GuitarDude Offline
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Joined: Nov 2004
Posts: 5,925
So Cal
Thanks for the input everybody.

It is a modification to the original note so I am leaning towards just reporting the increase.
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