We are a large bank and I have a technical data reporting question. We have a borrower that originated a loan in January and then later in the year (October) renewed the same loan. Can we report it as an origination AND a renewal?

No, an institution may only report one origination (including a renewal or refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted.

And when an increase is granted you report the original loan and the increased amount (not the total amount) separately or you can report them as one loan in the total amount in the same year.

I want to confirm my understanding of this scenario.... borrower originates a loan for $100,000 in January, so we report using code "N". In October of the same calendar year, the loan renews and $50,000 in new money is added. The loan number remains the same.

Would we report the $50,000 using code "I"? Basically, we would have the same loan number reported twice, but with different dollar amounts and action codes.

Happy Friday - Can anyone confirm the above scenario?

Thanks!

Sounds correct to me. There is no requirement to have a unique identifier when dealing with CRA reporting.

Although having a unique identifier will make importing your data into a CRA analytics and filing platform easier.