The main change to loans has no effect on small business/small farm reporting. It affects treatment of HELOCs that enter the repayment period FOR CALL REPORT PURPOSES ONLY (not Reg Z):
The Call Report instructions do not address the reporting treatment for a home equity line of credit when it reaches its end-of draw period and converts from revolving to non-revolving status. Such a loan no longer has the characteristics of a revolving, open-end line of credit and, instead, becomes a closed-end loan. In the absence of instructional guidance that specifically addresses this situation, the agencies have found "diversity" (read that as lack of consistency) in how these credits are reported in Schedule RCâ€“C, Part I.
Therefore, the agencies are proposing to clarify the instructions for reporting loans secured by 1â€“4 family residential properties to specify that after a revolving open-end line of credit has converted to non-revolving closed-end status, the loan should be reported in Schedule RCâ€“C, Part I, item 1.c.(2)(a) or (b), as appropriate.
In proposing this clarification, the agencies request comment on whether an instructional requirement to recategorize HELOCs as closed-end loans for Call Report purposes would create difficulties for institutionsâ€™ loan recordkeeping systems.
Not much else at all affecting lending.