OK - I've searched and searched and still can't seem to get a straight answer on these. All I want to know is:

Do I report these bloomin' things as small business loans or not?!?! (of course it's given that all other aspects of the loan meet the definition, yada yada yada...)

From the Guide to CRA: "Institutions are not required to collect data on loan commitments and letters of credit. They may, however, provide for examiner consideration information on letters of credit and commitments." (p.14)

Thank you! I swear I read that thing a dozen times trying to find this...can't see the forest for the trees I suppose.

Need a logger Becca? sounds like you're purposly trying to confuse yourself

It has definitely been known to happen! Well, not usually on purpose...

Is it just me or has today lasted FOREVER????

On the subject of reporting letters of credit, I was told by the FDIC that while an actual letter of credit is definitely optional, when the bank funds a loan in connection with the letter of credit AND if the bank reports that loan in RC-C Part II then we are to report that loan as a small business loan.

That was my understanding. As soon as it is funded, then we are required to report it, until then it is optional.

Again, depending on normal reporting standards, (size etc) that would be the case.