Latest comments for http://www.ababj.com , comment 0 to 3 out of 3 comments http://www.ababj.com Wed, 22 May 2013 21:15:43 +0100 FeedCreator 1.7.2 http://www.ababj.com/myblog/education-loans-to-get-cra-respect.html#pc_599 The amendment specifically says that it only applies to loans your bank originates. The Feds specifically said that purchased loans would not be covered within the definition of “low-cost education loans.” Although, having said that, there’s another piece to this that also comes into play. Even if an education loan doesn’t meet the requirements for “low-cost education loans” under this new section for QUALITATIVE consideration, they could still be considered a part of your pool of CONSUMER LOANS that you can receive quantitative credit for if you maintain data on that portfolio of lending for CRA purposes. So, its still possible for purchased loans (including education loans) to be counted within your Consumer Loans for CRA credit. As far as loans that you originate and then sell, the Feds didn’t address that in the amendment or in the preamble explanatory information. Since the language in the Reg just says “originated” I think that means literally “originated” regardless of what happens after that. I don’t see why you couldn’t get credit for originated loans that you then sell to someone else. But, buying a participation in a loan made by a specialty servicer – probably not, since you didn’t originate the loan. - Nancy D-C Fri, 05 Nov 2010 15:07:17 +0100 http://www.ababj.com/myblog/education-loans-to-get-cra-respect.html#pc_598 I don't understand your second point. Can we get credit if we originate the loan and then sell it (to a specialty servicer, for example)? What if we buy a participation in a loan made by a specialty servicer - can we get credit for that? - RC Fri, 05 Nov 2010 12:06:23 +0100 http://www.ababj.com/myblog/education-loans-to-get-cra-respect.html#pc_597 your blog did not address the amazing difficulties in ever making a loan where $1 is being used for any post secondary purpose (car loan, rent loan, book loan or tuition loan). Reg Z was amended this year to require numerous disclosures, including the borrower having to get a form from the college before a loan can be made - Sec. 226.48 - Limitations on private education loans - So the road blocks were already in place to ever helping out students. - gregg Fri, 05 Nov 2010 11:27:08 +0100