Skip to content
BOL Conferences
Forums · Active Threads · Forum Rules · Mark All Read · Log In
BankersOnline.com Forums Banker Forums CRA Not sure if this is CRA
Thread Options
#312385 - 02/04/05 03:57 AM Not sure if this is CRA
Anonymous
Unregistered

We've been seeing a lot of loans on the CRA LR that are made to individuals to purchase rental property. Some of the loans are unsecured and I am not sure that these should really be on the LR. We generally consider loans to purchase rental property business purpose but since some of the individuals are not "in the business" and are doing this like a side-line (i.e. the borrower's main occupation is a banker), that these are not small business loans. Also the collateral is 1-4 family. Is there something I may not be considering? I'm thinking these may be HMDA and not CRA.

Return to Top
CRA
#312386 - 02/04/05 05:24 PM Re: Not sure if this is CRA
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
The collateral being 1-4 family SFR excludes the loans from being reported as Small Business Loans. Look at the Call Report Definations for 1E and 4A. (Small Business)

If the loan is for a "Business Purpose" it doesn't matter if its not the borrowers full time occupation.
_________________________
Compliance Analysis and Research - Software for your CRA/HMDA analysis needs

Return to Top
#312387 - 02/04/05 06:08 PM Re: Not sure if this is CRA
Anonymous
Unregistered

Quote:

If the loan is for a "Business Purpose" it doesn't matter if its not the borrowers full time occupation.



Ok, I looked at little further in the CRA guide in the Call Report information and found where it states "also include loans to individuals for commercial, industrial, and professional purposes but not for investment or personal expenditure purposes." I'm thinking too hard these days thank you for your help.

Return to Top
#312388 - 02/04/05 09:40 PM Re: Not sure if this is CRA
CRAatBOK Offline

Power Poster
Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
Quote:

The collateral being 1-4 family SFR excludes the loans from being reported as Small Business Loans. Look at the Call Report Definations for 1E and 4A. (Small Business)

If the loan is for a "Business Purpose" it doesn't matter if its not the borrowers full time occupation.



Don, I see the Anon said the loans were unsecured. If they are unsecured and considered business purpose then they would be a 1. If they were secured by the RE then they would be HMDA, would they not?
_________________________
Life is not the way it's supposed to be. It's the way it is. The way you cope with it is what makes the difference.

Return to Top
#312389 - 02/04/05 10:38 PM Re: Not sure if this is CRA
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
You are absolutely correct, I did not read this correctly as it said some loans were unsecured and others were secured by 1-4.
_________________________
Compliance Analysis and Research - Software for your CRA/HMDA analysis needs

Return to Top

Moderator:  CRAatBOK, Kathleen O. Blanchard, Princess Romeo