Hi There,

We are struggling with how to report a $5MM community development eligible loan that is un-disbursed line of credit. Can we report the $5MM commitment if no money was drawn yet ???

Thanks for your help!! CRA help desk never got back to me 

According to the Guide to CRA Data Collection and Reporting, the full amount of the credit line is the amount that is considered originated.

Lines of Credit
Institutions must collect and report data on lines of credit in the same way that they provide data on loan originations. Lines of credit are considered originated at the time the line is approved or increased; and an increase is considered a new origination.
Generally, the full amount of the credit line is the amount that is considered originated. In the case of an increase to an existing line, the amount of the increase is the amount that is considered originated and that amount should be reported. However, consistent with Call Report instructions, if an increase to an existing line would cause the total line of credit to exceed $1 million, in the case of a small business line, or $500,000, in the case of a small farm line, the institution would not report the increase.

Hi,

I would like to piggy back of your answer, SoCalGal, with another question, if I may. My institution is moving into ISB this fall when our examination takes place. What is the balance of putting loans into the CRA bucket or the lending bucket? Because the way I understand it, is once you put a loan into either bucket there is no switching. So, how do I find the balance? I have 5 AA's total. 1 AA that is Underserved & Distressed, 2 others Underserved and the rest have no designation. Thank you in advance.

Best regards,

Bryan Armendariz

See my answer to your question in the other thread:

https://www.bankersonline.com/forum/ubbthreads.php/topics/2170985/cra-loan-test#Post2170985