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#2105724 - 11/02/16 06:58 PM Reporting Community Development Loans
KelliD Offline
Member
Joined: Jun 2015
Posts: 62
Can you report CD loans that you have reported in the past in your current year? If so, do I use the current balance of the loan for my annual report? Should I get a report of all CD loans, not just new for the year? Currently, I look over a YTD report of new loans that will qualify for CD and compile my list accordingly. If there is a process you use and can share, I would greatly appreciate it!

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CRA
#2105782 - 11/02/16 10:34 PM Re: Reporting Community Development Loans KelliD
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Each year you report what is new, including if something is a refinance of a prior loan or new money on a prior loan.

Otherwise, you do not repeat what has already been reported in prior years even if previously outstanding. Keep a running total in your records because you will need that cumulative data for your next examination. For an exam, you will show everything since the last exam...

show what is still outstanding just so that you can show what is "on your books"
show what is new since last exam even if paid off between exams
show what has been extended or refinanced at a maturity date between exams
show new money that has been added between exams

The goal is to say here is where we were, here is what has happened between exams, here is where we are now.

I never liked to just rely on reports from the system, we kept our own running total on a report with all of the explanatory data and notes on each transaction. That way we always knew what we had and what it was. Much easier to get our heads around and to explain to auditors and examiners. I do not recommend waiting until just before an exam to see what is in portfolio.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2105821 - 11/03/16 02:05 PM Re: Reporting Community Development Loans KelliD
RR Jen Offline
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RR Jen
Joined: May 2003
Posts: 3,760
Running and riding everywhere ...
^^^ Sounds like my CDL summary report. It has the following columns:

Original Note Date
Renewal/Modificaiton Date
Borrower Name
Original Loan Amount
Then the "hook" that qualified the loan.

I have all loans that will be covered in the upcoming exam period on the list. Each loan has an individual write up with quite a bit more detail.
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#2105984 - 11/04/16 01:33 PM Re: Reporting Community Development Loans RR Jen
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Originally Posted By RR Jen
^^^ Sounds like my CDL summary report. It has the following columns:

Original Note Date
Renewal/Modificaiton Date
Borrower Name
Original Loan Amount
Then the "hook" that qualified the loan.

I have all loans that will be covered in the upcoming exam period on the list. Each loan has an individual write up with quite a bit more detail.


That is what you need for a smooth exam experience.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2106204 - 11/07/16 04:29 PM Re: Reporting Community Development Loans KelliD
Tennismom Offline
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Tennismom
Joined: Jan 2004
Posts: 778
Although not regulated by the FED, our regulators (FDIC) suggested that we adopt a format similar to the one in this link.

https://www.kansascityfed.org/community/cdi/craonesource - See Community Development Tools

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#2106293 - 11/08/16 01:10 AM Re: Reporting Community Development Loans KelliD
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
That is a very typical format. You need every last piece of information. I would add a few things to that but it is fine as it stands.

Never wait until right before an exam to start gathering information.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2106713 - 11/09/16 07:53 PM Re: Reporting Community Development Loans KelliD
KelliD Offline
Member
Joined: Jun 2015
Posts: 62
Thanks everyone, good information for this newbie! I am new to my position as CRA Officer and my bank has only gone through one exam as a large bank. So I am setting up procedures and systems to track all of this information.

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