Interagency Q&A .22(a)(2) – 3: May an institution receive CRA consideration for home mortgage loan MECAs, in which it obtains home mortgage loans from others without actually purchasing or refinancing the mortgage loans?

Compliance > Regulation BB - CRA
Q:  § __.22(a)(2) – 3: May a financial institution receive consideration under CRA for home mortgage loan modification, extension, and consolidation agreements (MECA), in which it obtains home mortgage loans from other institutions without actually purchasing or refinancing the home mortgage loans, as those terms have been interpreted under CRA and HMDA, as implemented by 12 CFR part 1003?
 
A:  Yes.  In some states, MECAs, which are not considered loan refinancings because the existing loan obligations are not satisfied and replaced, are common.  Although these transactions are not considered to be purchases or refinancings, as those terms have been interpreted under CRA, they do achieve the same results.  A small, intermediate small, or large institution may present information about its MECA activities with respect to home mortgages to examiners for consideration under the lending test as “other loan data.”
 
 
 
This Interagency Q&A, and others, was released in July 2016.  The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately.  They may be found here:  http://www.ffiec.gov/cra/qnadoc.htm
 

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