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Tagged: CRA Reporting Codes
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June 28, 2023 at 12:23 pm EDT #341540nikipriceParticipant
I have a vendor stating that code 9 can only be used for a Consumer loan….Wouldn’t the “Other” code for consumer loans be coded as 7 (Other Secured Consumer Loans) or 8 (Other Unsecured Consumer Loans)? I’m trying to figure out when you would use 9 for consumer and I can’t make it make sense. Code 3 “Other Lines/Loans” would be used for Small Business loans that is secured by residential property, correct? If you have something that details the loan types, it would be great help so we can get this figured out. Here is how we breakdown the codes in our bank:
1 – Small Business Loan – any business purpose loan or line of credit with an originating amount of $1,000,000 or less that is secured by non-farm, non-residential real estate or not secured by real estate at all
2 – Small Farm Loan – any loan or line of credit with an originating amount of $500,000 or less that is secured by farmland (including farm residential or other improvements) or if not secured by farmland the loan proceeds are used to finance agricultural production (ex. Loan to purchase a tractor)
3 – Other Lines/Loans for Purposes of Small Business – “Non-HMDA” loan with an originating amount of $1,000,000 or less that is secured by residential property. (Ex. Loan to purchase a business secured by a residence)
5 – Motor Vehicle – any consumer purpose loan secured by a motorized vehicle, which includes boats
6 – Credit Card – issuance of a bank credit card
7 – Other Secured Consumer Loans – any consumer purpose, non-HMDA loan that is secured by collateral and does not fit any other category (would include lot loans)
8 – Other Unsecured Consumer Loans – any consumer purpose loan that is unsecured
9 – Other Loan – any loan not elsewhere classified, which should be business purpose or construction loans over $1 million, non-community Development business letters of credit, HMDA, and construction loans.June 28, 2023 at 1:37 pm EDT #341543pparksParticipantGood Afternoon,
What you have seems to come directly from the CRA File Specs document. Do you have that file document to present to your vendor to correct their thinking? It is not unusual for a vendor to be incorrect. A good vendor will see the regulatory document in front of them and correct themselves accordingly. Hopefully, you are working with a “good vendor.” 🙂
01 = Small Business Loan
02 = Small Farm Loan
OPTIONAL LOAN TYPES:
03 = Other Lines/Loans for Purposes of
Small Business
05 = Motor Vehicle
06 = Credit Card
07 = Other Secured Consumer Loans
08 = Other Unsecured Consumer Loans
09 = Other Loan DataJune 28, 2023 at 2:35 pm EDT #341544nikipriceParticipantYes, I have sent it to them and hopefully they will correct the issue. I just wanted to make sure I wasn’t misunderstanding the Loan Type codes.
Thank you.
June 28, 2023 at 2:41 pm EDT #341545nikipriceParticipantIs it your understanding that Code 9 is used for Commercial loans that do not qualify for codes 1 (Small Business), 2 (Small Farm) or 3 (Other Lines/Loans for small business)?
June 30, 2023 at 9:57 am EDT #341561Kimberly Boatwright, CAMS, CRCMKeymasterThank you PParks for jumping in and answering this! As follow up to the last question in the post, I has always been my understanding that you would use code 9 when the loans do not fit in any of the other options. I personally have not seen code 9 used but would be interested in seeing if any of our Banks have used it in the past.
July 3, 2023 at 2:00 pm EDT #341582nikipriceParticipantIf you have not seen code 9 used how are other financial institutions coding their commercial loans that are not Small Business, Small Farm or Other loans for purposes of small business?
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