Our card portfolio is on another system. Historically we never included these lines in our small bus. loans. We wish to start doing so with 2013 stats. As the cards are not accounted for on our cores system, we cannot add the cards to the file provided to the regulators (the one using the FFIEC standards). Can we, therefore, include these on the report we developed to account for the larger loans and which we put on a spreadsheet? We don't have a lot. maybe 25 total.

If you file an annual CRA submision, you need to combine these loans with your other small business submissions, whether by manually adding, importing separately into the FFIEC software, etc.

If you do not file an annual submission you can have a separate report.

Either way, the loans must be geocoded and properly coded for CRA type, revenue, etc.

OK, that helps.