Q: § __.22(a)(2) – 4: In addition to MECAs, what are other examples of “other loan data”?
A: Other loan data include, for example,
• loans funded for sale to the secondary markets that an institution has not reported under HMDA;
• unfunded loan commitments and letters of credit;
• commercial and consumer leases;
• loans secured by nonfarm residential real estate, not taken as an abundance of caution, that are used to finance small businesses or small farms and that are not reported as small business/small farm loans or reported under HMDA; and
• an increase to a small business or small farm line of credit if the increase would cause the total line of credit to exceed $1 million, in the case of a small business line; or $500,000, in the case of a small farm line.
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