Compliance Alliance Q&A 6/4/2019

Question:

We have two commercial lines of credit that originated in 2016 but were increased by $200,000 each in 2019. We did not have new disclosures signed, and we simply executed a loan modification for the loan amount increase to both files. Should these increases be reported on the small business LAR for this year or is this just for originations?

 

 

Answer:

Yes, the bank should report in this case because increases are treated as new originations for CRA purposes, as set out in the Guide here:

 A3. Institutions must collect and report data on lines of credit in the same way that they provide data on loan originations. Lines of credit are considered originated at the time the line is approved or increased; and an increase is considered a new origination. Generally, the full amount of the credit line is the amount that is considered originated.

 Page 12 at https://www.ffiec.gov/cra/pdf/2013_CRA_Guide.pdf

 

 

 

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