Does anyone know if loans to our affiliates should be reported under CRA?

if they would be reported on your call as small business, for example, then you would report them as such for CRA

similar, I guess, to employee loans reportable under HMDA

Thanks,

RubyB,

You have a choice if your are going to include your affiliate(s). If you do choose to report your affiliate loans you cannot pick and choose the loans. So if you have multiple affiliates then you will need to report all loans from those affiliates.

Pg 9 CRA Gettinr It Right

Affiliate Loans
Affiliate means any company that
controls, is controlled by, or is under
common control with another
company. The term “control” has the
meaning given to that term in 12
U.S.C. 1841(a)(2), and a company is
under common control with another
company if both companies are
directly or indirectly controlled by the
same company.
An institution is not required to
collect information on affiliate loans.
However, an institution that elects to
have its regulator consider loans by
an affiliate, for purposes of the
lending or community development
test or an approved strategic plan,
must collect, maintain, and report for
those loans the data that the
institution would have collected,
maintained, and reported had the
loans been originated or purchased
by the institution.

Bubs...I think that Rudy was referring to loans made by their bank TO their affiliates...not loans made BY their affiliates.

Otherwise, you'd be totally correct!

My bad

Check the Call Report instructions to see where the loan is to be reported. If your affiliate is a depository institution, the loan is reported on RC-C Line 2 and thus cannot be reported as a small business loan. Loans to insurance companies (companies NOT agents), loans to mortgage companies, and finance companies, etc., are reported on RC-C Line 9 and thus cannot be reported as a small business loan.

http://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_041_200706_i.pdf