CRA Reporting, Action Date, and Letters of Credit
Issue/Inquiry
With respect to CRA reporting, the Bank asks whether the date of action taken for a loan is the date of the closing or the date entered on the Bank’s system. The dates are usually the same, but in the case of loan modifications and closings, the date the documents are signed may be different from the effective date on the system. For example, an extension might be signed on November 15th, but the date on the system will be November 1st. Are evergreen letters of credit with a 60-day cancellation provision prior to maturity CRA-reportable?
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