Is a non-revolving loan that is to an individual for the purpose of short term real estate investments and is secured (abundance of caution only) by bare commercial land a small business loan?

The borrower's primary business is hotel management and part of the loan proceeds went to pay off a deed of trust that was recorded against the land.

Look at your call code. A small business loan would need to have a 04A0 or a 01E0 call code for it to be CRA Small Business reportable.

Not everbody has access to the call codes. Vacant land is not in the definition of small business.

My eyes are rolling...ABC my ars...umm nevermind.

Have you reviewed all loans similar to this to determine if the abundance of caution is appropriate? Comparing both the borrower rate, terms, stregnth, etc., against other "unsecured" loans of this nature? If you haven't, and your lender was just avoiding an appraisal or other bank policy, you should do as KC suggests and call it a type 9, non-CRA reportable loan since you took the land as collateral.

I agree with the type 9-non reportable. I really don't think the loan would have been made unless the collateral was taken. BTW we do have an appraisal. Thanks for your help.

I'd sure want to have that call report cleared up if they took this as an unsecured loan due to the BS ABC defination (Ok that's strong, but if an examiner reads this file they will agree). This is a data integrity issue you need to clear up, both because of CRA, and because your call report is not correct. That second issue costs money...real money, and sends the boss to jail...something we strive not to do