Interagency Q&A .26(b) – 4: Under the small institution lending test performance standards, will examiners consider both loan originations and purchases?

Compliance > Regulation BB - CRA
Q:  § __.26(b) – 4: Under the small institution lending test performance standards, will examiners consider both loan originations and purchases?
 
A:  Yes, consistent with the other assessment methods in the regulation, examiners will consider both loans originated and purchased by the institution.  Likewise, examiners may consider any other loan data the small institution chooses to provide, including data on loans outstanding, commitments, and letters of credit.
 
 
 
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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