I have a loan under $1 million that is commercial real estate property in the name of John Smith Family Trust. Can this be CRA reportable?

Yes. If the loan is secured by non-farm non-res real estate, and is $1 million or less it is a small business loan for CRA.

Thank you!

This is determined by how the loan is reported on the Call Report. For loans secured by non-farm non-residential real estate, purpose of loan and type of borrower have no bearing. The classification is totally collateral based.

What about an indirect automobile loan in the name of a family trust? They are coding it as c&i 04A0 just because it is in the name of the trust. The purpose is to purchase a vehicle with the vehicle as collateral. Do not have what the vehicle is actually being used for.

Call code 4 (C&I) has to have a business purpose. If that is how the bank is treating this, then that is how you report. Your only recourse is to review coding with those who established the bank's coding (lending and finance).