Interagency CRA Q&As

§__.42(a)(2) CRA Data Collection for Small Business Credit Cards

§__.42(a)(2) – 3 Q: How should an institution collect data pertaining to credit cards issued to small businesses? A3. If an institution agrees to issue credit cards to a business’s employees, all of the credit card lines opened on a particular date for that single business should be reported as one small business loan origination rather than…

§__.42(a)(3) Reportable Loan Location

§__.42(a)(3) – 1 Q: Which location should an institution record if a small business loan’s proceeds are used in a variety of locations? A1. 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…

§__.42(a)(4) Determination of Small Business Gross Annual Revenues Indicator

§__.42(a)(4) – 1 Q: When indicating whether a small business borrower had gross annual revenues of $1 million or less, upon what revenues should an institution rely? A1. Generally, an institution should rely on the revenues that it considered in making its credit decision. For example, in the case of affiliated businesses, such as a parent corporation…

§__.42(a)(4) CRA Data Collection of Small Business Gross Annual Revenues

§__.42(a)(4) – 2 Q: If an institution that is not exempt from data collection and reporting does not request or consider revenue information to make the credit decision regarding a small business or small farm loan, must the institution collect revenue information in connection with that loan? A2. No. In those instances, the institution should enter the…

§__.42(a)(4) Gross Annual Revenue Determination for Small Business Start-up

§__.42(a)(4) – 3 Q: What gross revenue should an institution use in determine the gross annual revenue of a start-up business? A3. The institution should use the actual gross annual revenue to date (including $0 if the new business has had no revenue to date). Although a start-up business will provide the institution with pro forma projected revenue…

§__.42(a) Gross Annual Revenue Versus Adjusted Gross Annual Revenue

§__.42(a)(4) – 4 Q: When indicating the gross annual revenue of small business or small farm borrowers, do institution rely on the gross annual revenue or the adjusted gross annual renew of their borrowers? A4. Institutions rely on the gross annual revenue, rather than the adjusted gross annual revenue, of their small business or small farm borrowers…

§__.42(b)(1) Required CRA Data Reporting

§__.42(b)(1) – 1 Q: For small business and small farm loan information that is collected and maintained, what dat should be report? A1. Each institution that is not exempt from data collection and reporting is required to report in machine-readable form annually by March 1 the following information, aggregated for each census tract in which the institution…

§__.42(b)(2) Required CRA Data Reporting for Community Development Loans

§__.42(b)(2) – 1 Q: What information about community development loans must institutions report? A1. Institutions subject to data reporting requirements must report the aggregate number and amount of community development loans originated and purchased during the prior calendar year.   Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016

§__.42(b)(2) Required Data Reporting – HMDA vs. CRA

§__.42(b)(2) – 2 Q: If a loan meets the definition of a home mortgage, small business, or small farm loan AND qualifies as a community development loan, where should it be reported?  Can Federal Housing Administration, Veterans Affairs, and Small Business Administration loans be reported as community development loans? A2. Except for multifamily affordable housing loans, which…

§__.42(b)(2) CRA Data Reporting on Affordable Housing Community Development Loans

§__.42(b)(2) – 3 Q: When the primary purpose of a loan is to finance an affordable housing project for low- or moderate-income individuals, but, for example, only 40 percent of the units in question will actually be occupied by individuals or families with low or moderate incomes, should the entire loan amount be report as a…