1. CRA reportable? Line of credit for maintenace/rental expenses secured by residential rental properties.

2. Always get confused with the income. For a small business loan, do you use gross sales or adjusted income?

1. Will not be CRA Small Business type 1 if primarily secured by residential real estate, whether or not HMDA reportable (if you report lines) but can be included in exam as CRA Type 3 Other Small Business. If you report revolving lines for HMDA, it is HMDA reportable if it meets HMDA purpose. If a refinance under HMDA can also be CRA Type 3 under refi exemption under CRA.

2. Gross Sales.