CONSTPERM Loan Category Missing For Farmland Loans (FFIEC-031, RC-C)
(Doc ID 2711207.1)
Last updated on SEPTEMBER 21, 2020
Applies to:Oracle Financial Services - Regulatory Reporting for US Federal Reserve - Lombard Risk Integration Pack - Version 8.0.9 and later
Information in this document applies to any platform.
Line item 1
As per the instructions the CONSTPERM loans are defined as: Loans written as combination construction-permanent loans secured by real estate should be reported in this item until construction is completed or principal amortization payments begin, whichever comes first. When the first of these events occurs, the loans should begin to be reported in the real estate loan category in Schedule HC-C, item 1, appropriate to the real estate collateral. For purposes of these reports, a combination construction permanent loan arises when the lender enters into a contractual agreement with the original borrower at the time the construction loan is originated to also provide the original borrower with permanent financing that amortizes principal after construction is completed and a certificate of occupancy is obtained (if applicable).
The instructions do not restrict the usage of these loans to any particular line item within line items of HC-C 1. The current Oracle configuration uses it for line item 1.a, 1.c, 1.d and 1.e, but excluded line item 1.b from this category.
Clarification required from Oracle on why Loans secured by Farmlands HC-C 1.b are being excluded from using CONSTPERM loans.
An example of this could be a CONSTPERM loan given for the construction of barn where the collateral is farmland.
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