Under loans to small businesses in the guide it lists examples of nonfarm nonresidential loans secured by real estate, including liens on churches, hospitals, educational and charitable organization properties. Then on the next page under excluded commercial & industrial loans it says that loans to nonprofit organizations, such as hosptials or educational institutions are to be reported on the call report line 9 other loans, which are not small business loans. This seems contradictory. Can anyone explain this to me?

Loans to non-profits that are unsecured or are secured by something other than real property go on line 9. These loans are not small business loans--but depending on the loan purpose they could be commuinty development. If a loan to a non-profit is secured by commercial property and the loan amount is under 1 mil it has to be reported as a small business loan.

I agree with Risa. One way to think of it is, if the loan is secured by real estate, then the type of real estate determines how the loan is classified. However, if the loan is not secured by real estate, that's when you look at the type of borrower and/or the purpose of the loan.

Risa and Great Blue are both correct. You have to comb through those arcane Call Report instructions to find that a loan to a non-profit cannot be reported on Call Report line 4a, but if the loan to a non-profit is secured by "non-farm/non-residential" real estate, then you report it on line 1e.

Lines 4a and 1e are included in the Loans to Small Business segment of the Call Report and thus new loans, increased loans, and renewals that would be reported on either of those lines would be included in your CRA Loan Register.

For me, it's another Data Scrub that I have to conduct. I look through all loans under $1MM that are NOT secured by commercial real estate, and then I start reviewing names for those that could be non-profits. "Bob's Machine Shop" is probably a for-profit. "Association for the Sightless" is probably a non-profit. Alas, more art than science!