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#1812801 - 05/09/13 07:39 PM pif during exam period
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Investment paid off during mid-year of the exam period. Can we count these or are they not permissible? If not, is there something in the FAQs to this effect?

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CRA
#1812877 - 05/09/13 09:05 PM Re: pif during exam period Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
If it was active during any part of the exam period keep it on your list. Do NOT remove paid off loans, matured investments, etc. Your should have a running list of investments with date of initial investment, purpose, etc (of course, to demonstrate CRA qualification), any additional investments (perhaps investment of interest/dividends/returns of capital), and maturity date. For the exam everything that was in effect in any part of the exam period gets comsidered.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1813507 - 05/13/13 01:30 PM Re: pif during exam period Trees
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Examiners took off prior period loans and investments that were pif during the current time period. Not sure how to deal iwth this. Should I ask them for the reference number.

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#1813557 - 05/13/13 02:55 PM Re: pif during exam period Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
It all depends upon what you are referencing. They count toward your "total portfolio" but not toward "originated in the exam period". You are judged on the entire outstandings but also on effort expended during the exam period.

For example, if a bank rested on its laurels because it had a good portfolio of investments or community development loans for CRA from prior periods and did nothing during this exam period, those prior items still outstanding won't help much.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1813770 - 05/13/13 09:41 PM Re: pif during exam period Trees
Trees Offline
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Joined: Apr 2005
Posts: 4,013
We're have been pretty activie in this period as well. We are just trying to understand the examiner's point. We discussed this further. Investments/loans made in the prior period and which pif during the current period and which were zero at year end do not count. Doesn't matter if they had a balance midway.

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