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#2288004 - 08/24/23 03:18 PM Call report code - multiple collateral types
JoeM86 Offline
Junior Member
Joined: Dec 2012
Posts: 45
I've read through the call report instructions glossary regarding loans secured by real estate, which (in simple terms) states that a loan is considered secured by real estate if the value of the real estate collateral is greater than 50% of the principal amount at the time of origination. The glossary goes on to say that a loan meeting that criteria is to be reported in RC-C Part 1, item 1 regardless of purpose, how the loan is categorized internally, etc.

What I'm not quite sure about is the following: if I have a $1 million loan secured by $1 million in real estate and $2 million in non-real estate collateral, does the non-real estate collateral factor into the call report code decision since it would represent the majority of collateral in this example? The call report glossary wording causes me to read it as once you've satisfied the secured by real estate criteria, you stop there. Just curious if others read it the same way. I haven't found an explanation for evaluating multiple collateral types on one loan.

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Lending Compliance
#2288010 - 08/24/23 04:49 PM Re: Call report code - multiple collateral types JoeM86
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,401
Galveston, TX
I would be checking with my external accounting firm, as they are the ones that attest to the fact that the bank's books are being kept accordingly and reporting is accurate.
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#2288035 - 08/24/23 10:23 PM Re: Call report code - multiple collateral types JoeM86
fmissle Offline
Diamond Poster
Joined: Jul 2007
Posts: 1,026
Pac NW
I think this part further on might help, but obviously the safe course of action is to check with your firm as rlcarey states.

Quote
Only in a transaction where a lien or liens on real
property (with an estimated collateral value greater than 50 percent of the loan’s principal amount at
origination) have been taken as collateral solely through an abundance of caution and where the loan
terms as a consequence have not been made more favorable than they would have been in the
absence of the lien or liens, would the loan not be considered a loan secured by real estate for
purposes of the Reports of Condition and Income.
In addition, when a loan is partially secured by a
lien or liens on real property, but the estimated value of the real estate collateral at origination (after
deducting any more senior liens held by others) is 50 percent or less of the principal amount of the loan
at origination, the loan should not be categorized as a loan secured by real estate. Instead, the loan
should be reported in one of the other loan categories used in these reports based on the purpose of
the loan.

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