I have a situation here that I am stuck on. There is a CDL that needs to be reported from a battered women's shelter. The trouble is, they won't give out their physical address. I was just going to use NA for MA, state code, county code, and census tract on my CRA sheet, but I looked in my HMDA book I got from a workshop and it says that under CRA regulation, you must report property location for all loans and applications, whether or not the property is in an MA. They do have an address for a Thrift shop that they use for these women that need clothes, supplies, etc. Could we use that or are there any suggestions as to what we need to do? Thanks in advance!

I might be out in left field here but I don't think you have to have an address for a CDL. I looked at the reg and it doesn't indicate you must. I would indicate in my write up that the address in confidential but would include the area served by the shelter.

I agree with KC you will only have to prove that the loan meets the the criteria for CDL. As for location you will need to explain if it is or out of your AA.

Please rethink this in a total regulatory way. How would you explain this in a BSA/AML exam. You have a loan to a borrower, but you don't know where the borrower uses the loan proceeds and they refuse to tell you. If that is the case you would not be able to make the loan. If you can explain that it is in or out of your AA, the regulator will ask how you know that if you don't know where they are. While I understand the sensitivity involved, the borrower name is not reported to anyone and if you are following proper procedures you data and files are secure.

use the gift shop address if the loan is to run the gift shop.

For a loan to a woman's shelter it is quite possible that while the proceeds are being used at the undisclosed address, the business office address is different and can be disclosed for loan purposes. I still think you could get credit by using the purpose vs the location.