FRB FAQs-What is the most appropriate way to establish the loan location, for example, if the loan is secured by real estate and there is an alternative business location? Can we report the location of the collateral as the reported loan location?

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Q:  What is the most appropriate way to establish the loan location, for example, if the loan is secured by real estate and there is an alternative business location? Can we report the location of the collateral as the reported loan location?
 
A:  Q&A ___.42(a)(3)-1 (page 11669 of the Federal Register notice ) addresses the loan location to be recorded. Specifically, an 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. A loan location based solely on the collateral location would be inappropriate.
 
 

This can be found in - CRA FAQ#10 of the FAQs.  The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/

 

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