Help - This is our first year of data submission.
I have a loan for $700,000 made to a married couple and secured by commercial property they own individually (not in the name of their business). Yes - the funds went into the business, but the loan is to individuals and the property is owned by the individuals. Is this a "small business" loan because it is Call Report coded 26R? HELP!

A loan for a business purpose, secured by non-farm, non-residential property, for an amount of $1Million or less, is reportable on your CRA Loan Register as a small business loan.

Welcome to the land of CRA Business Loan reporting - your Oddessy is just beginning!

It does not matter that your borrowers are individuals, the loan meets the definition of "Small Business Loan" for the Call Report. The Code you reference appears to be an internal code for your bank, since the Call Report line for the loan you referenced would be 01e in Schedule RC-C.

Thanks so much - none of this really makes much sense to me! A 26R as defined by our call reporting system is "non-farm, non-residential real estate." Anything in this category is considered to be a "small business" loan so long as the loan amount is $1 mm or less.

Diana, check out the tools in this post for some assistance and if you haven't already, ask your regulator if they'll do a class for you on this transition. Mine came and did 2 or 3 hours which both educated senior management and helped assure me I'd have the resources and cooperation needed with the new requirements.

Wow! Thanks Andy - I would have never thought of asking for an instructional seminar from the regulators. Thanks for the link also.

I'll vouch for Andy's advice - bringing the regulators in really works well, and in my case it was very well received by senior staff.

The only thing I'd add is a link to the Call Report instructions and a suggestion that you sit down with your CFO (or whoever prepares the bank's Call Report) and make sure your loan coding is correct. Do some sampling...