Skip to content
BOL Conferences
Thread Options
#2301761 - 09/17/24 07:12 PM Maturity date required?
Lori01 Offline
100 Club
Joined: Jan 2007
Posts: 186
VT
We have a line of credit that matured. We renewed it but changed it to open ended, instead of having a new maturity date. We reported this line because a MOD was signed. In the future we will "review" the line, but because with the open ended feature of the loan there will be no "New" maturity (or signed MOD agreement) so we will not report the loan beyond this most recent renewal
An examiner is telling me I should NOT have reported the line when it was extended because quote: "A reportable small business loan should have a maturity date."

I don't recall EVER hearing that before. I don't see it in the Q & As or in the guide to reporting CRA data. Am I missing something?

Return to Top
CRA
#2301879 - 09/23/24 12:44 PM Re: Maturity date required? Lori01
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 84,650
Galveston, TX
"An examiner is telling me I should NOT have reported the line when it was extended because quote: "A reportable small business loan should have a maturity date.""

Time to ask them for a citation.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2301967 - 09/25/24 12:01 AM Re: Maturity date required? Lori01
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,128
Connecticut
Small business loans that are (1) originated, (2) refinanced or (3) renewed are reportable under CRA. A refinanced loan is a loan that pays in full an existing loan and a renewed loan is one that has its maturity date extended. Demand loans are typically not qualified as a renewals after they are originated even though it's common practice in secured revolving lines of credit using loans callable on demand because the "renewal" technically does not extend the maturity date since the loan is callable on demand. There is a once per year per loan limitation too.
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

Return to Top
#2302161 - 10/01/24 07:33 PM Re: Maturity date required? Lori01
Lori01 Offline
100 Club
Joined: Jan 2007
Posts: 186
VT
I agree with what you are say Len, but it this case the loan didn't start off as a demand loan. It had a maturity date. AS that date was coming due soon, we renewed the loan by extending it....but that extension turned the loan into a demand loan.
I'm saying I can claim this renewal because the prior term was about to expire.
Going forward I would not be able to claim this loan again because in the future it would just be a review.

Return to Top
#2302163 - 10/01/24 07:36 PM Re: Maturity date required? Lori01
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 84,650
Galveston, TX
Not Len, but I agree with you. I do think that is what he was getting at though. It was going to be a one and done renewal.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2302285 - 10/04/24 06:39 PM Re: Maturity date required? Lori01
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,128
Connecticut
I agree.
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

Return to Top