Skip to content
BOL Conferences
Thread Options
#2295806 - 04/11/24 04:51 PM GAR for renewal
Carolina Blue Offline
Platinum Poster
Carolina Blue
Joined: Jul 2005
Posts: 961
Lost in a regulatory fog
New to large bank reporting and need some confirmation. Loan originated last year is maturing now. We did a modification last month to push the maturity forward 1 month. Based on my understanding, this modification transaction is a reportable loan. If reportable, then I need help with GAR. Loan from last year clearly shows the business is well over $1 million and was reported that way, but if underwriting approved the maturity modification with no financial analysis, then do we now report the GAR as 3?

Return to Top
CRA
#2296134 - 04/18/24 08:29 PM Re: GAR for renewal Carolina Blue
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,128
Connecticut
The idea is not to collect data for the sake of collecting data. It's to collect accurate and meaningful data. I am sure that the credit decision was based on the financial information about the borrower you have in file, You wouldn't have extended the maturity date without some financial information and unless you know the GAR dropped below the $1MM level you must know that it remains above that level and I would suggest you code the GAR accordingly
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

Return to Top