I'm finding that the people in my bank that are responsible for identifying and inputting CRA loans (small biz/farm) really don't know what a CRA loan is. They have barely even heard of a call code, they didn't realize the revenue code really mattered and they didn't know that loans secured by residential real-estate were not reported (primarily our home construction loans to businesses). Despite all of this, our institution has never run into a problem with its submitted CRA data.

So, now the CRA data is under my management and I'll be damned if we just keep reporting data incorrectly. I feel like I'm starting from ground zero though.

My main question is are there only certain call codes that should be reported on the CRA LR (01E0, 04A0 and 01B0)? My next question is should loans that meet the CRA small biz definition that are coded different (say 01A0) be reported as other lines/loans for small biz and do we receive full credit at the exam for these "other" loans?

I know that our CRA LR should reflect our call report, but how are all small business loans identified on our call report (is it all of the 01E0s and 04A0s)?

To sum it all up, I understand CRA, I don't really understand the call report but I know the two need to reflect one another. Also, my bank needs all of the CRA help it can get and I hate to do anything that is going to take away from our CRA credit.

Thank you in advance for your input.

There are definations for each item on the call report. There are definations that describes what items are to be reported in the 1e and 4A for Small Business and Ib and 3 for Small Farm. If you have a Small Business Loan colateralized by 1-4 sgl family it may not qualify to be reported on the call reports as 1E or 4a. It will need to be reported in one of the other call report categories. However, you can code the loan with a CRA Loan Type 3 on your LAR.(Other lines and loans for small business purposes) While not reported on the LAR you can ask examiners to review them for additional CRA credit. Its a defination of Abundance of caution thing, which is to long to post here, But do a search and you will find plenty of information about this.

Technically, only loans that meet the defination for loans reported as 1E and 4A on the call report should be reported on the LAR as Small Business Loans.

Correcting incorrect reporting is not going to take away from your CRA reporting as those reported incorrectly should not be reported anyway. It will probably save you a lot of time rescrubbing and refiling if examiners find enough incorrect reporting.

You may not have had a problem with your submitted data as examiners haven't reviewed it in a CRA exam yet. If thats the case you may have a problem.