Consumer Compliance Outlook 2Q 2011 – CRA – What is the most appropriate way to establish the loan location, for example, if the loan is secured by real estate and there is an alternative business location?

Compliance > Regulation BB - CRA
Q:  What is the most appropriate way to establish the loan location, for example, if the loan is secured by real estate and there is an alternative business location? Can we report the location of the collateral as the reported loan location?
 
A:     Q&A ___.42(a)(3)-1 (page 11669 of the Federal Register notice ) addresses the loan location to be recorded. Specifically, an institution should record the loan location by either the location of the small business borrower's headquarters or the location where the greatest portion of the proceeds are applied, as indicated by the borrower. A loan location based solely on the collateral location would be inappropriate.
 
 
ADDITIONAL INFORMATION:
This information was obtained from the Federal Reserve’s Consumer Compliance Outlook website and related materials from the November 2010 webinar on “Tips for Reporting Accurate HMDA and CRA Data,” which may be accessed here:  https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/
Users are advised that references to CRA Interagency Q&As may have been updated since that webinar.
 

Add Feedback