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#562651 - 06/06/06 05:28 PM Modifications
I Comply Offline
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I Comply
Joined: Nov 2004
Posts: 57
The more I read sometimes, the more I get turned around on even the easiest questions...

What if you have loan ABC for $50,000 for a term of 5 years made in January.
In November, you do a modification only to extend the maturity date to 7 years...everything else stays the same.

What would you report on your CRA LAR?

In doing some questioning here....I get the response that you would report it Twice...once for a term of 5 years and once for a term of 7 years. I to not agree..that's double reporting.

Also, what if you keep extending the maturity date of an existing business line of credit, do you get to report the original note amount year after year?

Or, even if it was a reg. loan not line, just b/c you extend a maturity date, does that warrant putting it on the LAR year after year?

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#562652 - 06/06/06 05:37 PM Re: Modifications
Len S Offline
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Joined: Oct 2004
Posts: 2,150
Connecticut
Believe it or not, you really would report the loan twice because refinancings and renewals are both reported under CRA. A renewal involves an extension of the maturity of the underlying note. And yes, you would report annual extensions of lines of credit (unless the underlying note is callable on demand and is not rewritten in which case it is not considered refinanced or renewed) subject to the once per year rule. Technically, you could extend a $50,000 day note and refinance or renew it every 90 days and you would report it 4 times for the year.
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#562653 - 06/06/06 08:21 PM Re: Modifications
Mrs. Rizzo Offline
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Posts: 10,392
Curled up by the fire...
Now I'm confused (doesn't take much..ha ha)
I thought that if you made a loan say for $30,000 on 01.01.06 with a one year maturity you would report it as such and the only way you could report it again in the same year would be if you increased the funds???
And if you made a 6 month loan for $30,000 on 01.01.06 that was increased to $50,000 and extended for another 6 months at maturity that you could only report the increased amount??
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#562654 - 06/06/06 09:08 PM Re: Modifications
Len S Offline
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Joined: Oct 2004
Posts: 2,150
Connecticut
Lyndsey, I have to amend my response slightly. There is a once-per-year limit on refis and renewals of the same loan (and line of credit). However, a series of renewals or refis of the same loan in subsequent years can be reported once each year. In my haste in my original answer (I was on my way to a meeting) I didn't properly qualify the limit. And you are correct that you would report subsequent increases in the same year. However, if a borrower takes out a 90 day note and pays it off and subsequent to the payoff takes out another note, both borrowings would be reported even if both loans should be for the same amount. So you could have a situation where a borrower takes out a series of short term notes, pays each note in full and then borrows again and you would report each loan (assuming each was qualfied as a small business loan in the first place) unless the borrowings were under a line of credit in which case the line would be reportable if it was for $1 million or less. My apologies for the confusion caused by my original response.
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#562655 - 06/06/06 09:28 PM Re: Modifications
Mrs. Rizzo Offline
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Mrs. Rizzo
Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
Thanks Len!
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#562656 - 06/07/06 01:28 PM Re: Modifications
I Comply Offline
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I Comply
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Posts: 57
Thank you Lyndsey, that was the same reaction I had but hadn't had a chance to respond. I think I'm clear on it now.

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#562657 - 06/07/06 01:29 PM Re: Modifications
I Comply Offline
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I Comply
Joined: Nov 2004
Posts: 57
...And Len for your help.

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