Interagency Q&A .42(c)(1) – 1: What are the data requirements regarding consumer loans?

Compliance > Regulation BB - CRA
Q:  § __.42(c)(1) – 1: What are the data requirements regarding consumer loans?
 
A:  There are no data reporting requirements for consumer loans.  Institutions may, however, opt to collect and maintain data on consumer loans.  If an institution chooses to collect information on consumer loans, it may collect data for one or more of the following categories of consumer loans:  motor vehicle, credit card, home equity, other secured, and other unsecured.  If an institution collects data for loans in a certain category, it must collect data for all loans originated or purchased within that category.  The institution must maintain these data separately for each category for which it chooses to collect data.  The data collected and maintained should include for each loan
 
•  a unique number or alpha-numeric symbol that can be used to identify the relevant loan file;
•  the loan amount at origination or purchase;
•  the loan location; and
•  the gross annual income of the borrower that the institution considered in making its credit decision.
 
Generally, guidance given with respect to data collection of small business and small farm loans, including, for example, guidance regarding collecting loan location data, and whether to collect data in connection with refinanced or renewed loans, will also apply to consumer loans.
 
 
 
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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