How do we report a construction-perm loan on commercial real estate for CRA when reporting it as a code 1A on the call report during the construction phase? Do we still include it as CRA type 1 (loans to small business) since it eventually will be classified as a code 1E1 for the call report when the construction is complete?

thanks,

Report when complete and the category changes.

Or when amortization begins...per call report rules.

If the amortization period begins in 2016, can we still report it under type 9 (other) for 2015 and report it again in 2016 under Small Business type 1 when the call code changes to 1E1?

thanks,

Not if it is all one note, with no extended maturity date via a new note or modification.

Oh that's right - unable to report it in 2016 with an original loan date of 2015 (only one note). We will report it as type 9 in 2015.

thank you.