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.