It is very important to keep the Call Report instructions handy for classifying loans. Line 1e, which is for non farm non residential real estate and broken further doen into 1e1 owner occupied and 1e2 owner occupied, says to include:
"Secured by nonfarm nonresidential properties. Report in the appropriate subitem (on the FFIEC 041, in column B; on the FFIEC 031, in columns A and B for large institutions and highly complex institutions – as defined for assessment purposes – with foreign offices, and in column B for all other institutions with foreign offices) loans secured by real estate as evidenced by mortgages or other liens on nonfarm nonresidential properties, including business and industrial properties, hotels, motels, churches, hospitals, educational and charitable institutions, dormitories, clubs, lodges, association buildings, "homes" for aged persons and orphans, golf courses, recreational facilities, and similar properties."
Your collateral falls into this category and is therefore not residential, it will be reported as a small business loan because it is in an amount of $1million or less regardless of community development. You can point this out to examiners if you wish.
Refer to the CRA q and a for information on special rules for ISB banks if the bank in question is an ISB.
Previous Thread
Index