Q: § __.42(a)(3) – 1: Which location should an institution record if a small business loan’s proceeds are used in a variety of locations?
A: The 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.
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