Our customer, John Doe, has a cattle operation. He recently obtained a loan individually, which is secured by cattle and made for the purpose of purchasing a rental property. It is unclear from the file documentation if he is in the business of rental properties as well as cattle or if this is the only rental property he has purchased.

How would we code this on the call report? Would it be a 4a (going by the call code definition that includes loans to farmers for C&I purposes) or is this considered a consumer loan as a personal investment?

Purchasing a rental property...which could be a retail store, an office building, an apartment building, a 1-4 family home.....would be a business purpose loan.

Review the Reg Z commentary re exemptions.

The loan is not real estate secured so it would be C&I.

Thank you!