Regarding CDLs - for large bank exams I know that if the loan is reported on the SBR or HMDA then you cannot get CDL credit for it. I just ran across old CDL worksheet that includes the following - is this correct?

Is the loan a small business, small farm, consumer, or home mortgage loan (except for multi-family housing)? ____ Yes ____ No. If no, go to 4. If the answer is yes and the bank is NOT being examined as an intermediate small bank, STOP. The loan cannot be reported or considered in the evaluation as a community development loan. However, the loan’s effect may be included in the narrative section of the PE; keep in mind that the bank has already received positive consideration under another part of the CRA evaluation for this loan.

If the answer is yes and the bank is being examined as an intermediate small bank, the bank has the option for the loan to be considered as a community development loan. If the bank has requested the loan be considered as a community development loan, then go to 4. If the bank has NOT requested the loan be considered as a community development loan, STOP.

Yes, ISBs can elect to have some small business loans or HMDA loans reported as community development for the exam. They remain in the small business loans on the call report and HMDA for the HMDA submission. The change is only within the exam numbers.

The information is here in the CRA q and a:

http://www.ffiec.gov/cra/pdf/2010-4903.pdf

Thank you - I was just about to search the FAQs. Thanks for the link.

An important caveat: If you are an ISB and are a HMDA reporter you don't get the election for HMDA reported loans. You get the elective only if you are not a covered institution. Also, if you are an ISB and voluntarily report your CRA data annually you don't forfeit this elective for exam purposes.

Bear in mind that multifamily properties are double reported for everyone, if CRA eligible.

One clarification to my previous comment: while you don't forfeit the elective for small business loans with CD qualifications by voluntarily filing your CRA data as an ISB, you cannot claim the elective no matter what if you are a HMDA reporter. The elective simply is not available for HMDA data reported by HMDA covered institutions. Sometimes bankers confuse the first elective with the second. The only time you can get CD lending credit for HMDA-reported loans is for multifamily affordable housing mortgages. If you are a HMDA reporting bank you cannot claim CD credit for single family mortgages even if they finance affordable housing.