The more I read, the more confused I am.

The little asterisk and foot note in the Call Report instructions (and referenced on page 46 of the CRA Data Collection & Reporting Guide) are what's doing it to me.

We are to EXCLUDE commercial construction and land development loans with maturities of 60 mos or less from CRA small business reporting. Then the asterisk appears. After reading all about the 03/31/01 "change", I have come to the conclusion that you still DO NOT report long-term commercial construction loans secured by commercial RE for CRA Reporting and that the asterisk just moves these types of loans to another section of the call report that is still EXCLUDED from CRA small business reporting (1.a.).

Did I understand that correctly?

Do I at least get a "stump the gurus" prize? Seriously, can any one help on this? It would be greatly appreciated.

bump

Are you saying that you've extended a construction loan with a maturity of more than 5 years? What is your client building that requires "construction" that exceeds 5 years? Is this a construction to permanent mortgage? I think we need more specific details to respond to your question about what appears to be a very unusual loan situation.

If it's construction/perm you need to treat it like a permanent loan which would be reportable (depending on borrower and size of course).

That would be 1e on your call report.

In the call report instructions is a line that says (I'm paraphrasing) "Sometimes a loan looks like more than one category. Categorize it by the preponderance of Collateral, Borrower and Purpose". In this case, I'm going to assume you have a commercial building, commercial borrower and a purpose of construction/perm financing. If those assumptions are correct, 1e would be appropriate.