I seemed to have had a brain lapse. Is a commercial loan for investment purposes secured by a 1-4 Family residence reportable under CRA? This loan is not HMDA reportable, but will CRA apply?

It would be a type 3 loan. These are not submitted on the LR but can be saved for the examiner to review during an exam if you need to.

For the record All loans are applicable to CRA. It's just a matter of what type they are that determines if they're submitted to the feds on the loan register. Type 1 and 2 deals are submitted, all others are usable as CD loans if they qualify, or can be analyzed for other reasons.

Our CRA software asks for Property Location. If the loan is secured by real estate, would the collateral's address be used?

You are allowed to use either the location of the proceeds or the business address. The fact that it is secured by a real estate may or may not play into that. If they invested in that residence, then go ahead and use that, but if not, use the main office address of the business.

Whatever you do, you need to be consistent. Either always use proceeds address, or business address, and don't choose based on census data (ie the lowest income tract) and you'll be fine.

This is probably a stupid question, but I won't know if I don't ask? Where do you get the type 3, type 9 etc? Thanks

Type 3's are Other Loans and Lines for Small Business Purposes. These are loans that do not meet all the criteria to be classified as Small Businesss type 1 loans. Usually they are collateralized by 1-4 residential property perhaps taken as an "abundance of caution". While these loans are not reported in your annual submission you can ask examiners to consider them for additional CRA credit.

Type 9's are "Other" consumer loans not classified by any of the other consumer loan type codes.

All consumer type loan codes 3-9 are not required to be reported. It is at the option of the bank to do so,unless due to its large volume of consumer loans, examiners have requested the bank to report them.

Thank You

Actually, just a quick clarification that I'm sure Don meant to say

Type 04 through 08 are consumer codes which vary depending on collateral type:
04 = Home Equity
05 = Motor Vehicle
06 = Credit Card
07 = Other Secured Consumer Loans
08 = Other Unsecured Consumer Loans

Type 1 is small business and type 2 is small farm
Type 3 is small business secured with residential real estate and type 9 is all other loans which do not fit in the above 8 types (this means all business loans not 1 or 2) ie large farm loans, loans over one million to businesses who are not farms, loans to non-profits that are not reportable, loans to schools, governments, banks, construction loans, raw land loans....on and on. All other "business" loans not reportable basically.

No I meant to say 3-9 as those are the optional reporting loan type codes per the 2004-2005 CRA File Specifications in the CRA Data Collection Software, and actually have been for several years.

Not to sound like a broken record, but a construction loan secured by a vacant lot, coded as a 1, is reportable? I have told by Mr B (compliance attorney) at an association I will not name, that a construction loan secured by vacant land is NOT reportable. Could CRA be any more gray? (I am a disbeliever in call codes! I've been bitten too many times!)

Don I was just confused by the line that said: "All consumer type loan codes 3-9" and just clearing up that the types weren't all "consumer" but you are quite right, they are all not reportable Sorry if I confused more!

CM, no it would not be reportable. Looking at the VERY small little line that accompanies the CRA type is not enough to determine reporting specifically. In this case, detailed review of type 1 would show that it would not be reportable (and that, sorry to say, comes from the call codes)

Dawnie-I am fairly new to this and trying to get my arms around the call report issue. If you have a cra type 3 loan where does it fall on the call report? Our bank is purpose code driven and the purpose code is the same for type 1 and 3, so they get reported on the same line on the call report (I think). Can you clarify for me?

It all depends on why the loan would be considered a CRA Type 3 loan. If it was because the loan has residential real estate as collateral that would be in a different section of the Call Report than a loan that exceeds the size limit ($1,000,000). There are a number of different reasons that can lead to a type 3 code and each one would potentially be reported in a different section of the Call Report.

Well Anon...actually there is only one reason for a type 3 on the LR...and that is because of residential collateral being involved and below one million. If it were a loan size issue, (over one million for instance) that would be a type 9 loan.

Your purpose code should not be the same for a type 1 and 3. If it is, and that is all you're using to drive the call report, you need to consider an allowance for your future regulatory files

A type 3 could fall under 1c (multiple choices in that area) or perhaps it could fall under 1 a, or it could be in 8 maybe if you're being creative. You really need to review your purpose code list and attach an appropriate call report code and CRA code option to it. For instance I have a loan purpose 144 Conventional 1-4 Family 1st Lien, Non-HMDA Commercial purpose, which can be a CRA type code 3 or 9. My Call report system knows that this rolls up via the purpose code to a residential real estate secured loan, and then further notes the first lien.

I of course have a code for a similar loan in a junior lien position.


You said (first Anon) that you think 1-3 roll up to the same line. I would highly suggest that you gather up your purpose codes and march into the area of your bank that prepares the call report and find out what line each item carries up to. I found errors in mine, which we then fixed. But we now do a regular check whenever we develop a new code so that they are all reporting correctly throughout the bank.

Thanks Dawnie, it looks like I need to do some research on my end to make sure everythings is rolling up correctly to the call report.

Type 04 through 08 are consumer codes which vary depending on collateral type:
04 = Home Equity
05 = Motor Vehicle
06 = Credit Card
07 = Other Secured Consumer Loans
08 = Other Unsecured Consumer Loans

Type 1 is small business and type 2 is small farm
Type 3 is small business secured with residential real estate and type 9 is all other loans which do not fit in the above 8 types (this means all business loans not 1 or 2) ie large farm loans, loans over one million to businesses who are not farms, loans to non-profits that are not reportable, loans to schools, governments, banks, construction loans, raw land loans....on and on. All other "business" loans not reportable basically.

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HRH, would it be possible to give a source for the code 9 types you stated above? What I need is to be able to show that commercial construction loans should be listed as "other", and not "residential 1-4 family"

CRA Code classifications can be obtained from the FFIEC Data Collection Software. Look in the help file under File Specifications.

You can also go the the FFIEC web site and in the search criteria and enter "cra loan types"

There is no cra loan type code for Residential 1-4 family. There is one for HMDA reporting. To obtain HMDA codes do the same as above except use HMDA software and search criteria.

Thanks for the quick response and info Don.