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#2118674 - 02/17/17 02:57 PM Small Farm Loans-2 policy questions
Bec Offline
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Bec
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The Great White North
We have just joined the ranks of a large bank CRA reporter! Yay!!!??????
Attempting to enhance our policy and procedures and stumbled across small farm loans. My bank does not typically delve into small farm loans, or any farm loans. In fact, if someone comes in and inquires about a farm loan, we actually refer them to a competitor to which is an expert in all things ag. So the question is, should I leave small farm loans out of the policy? It is all over the examination manuals and sample policies which leads me to believe that we should keep it in there in the happenstance that we should originate a small farm loan and it would qualify, but it really isn't our practice to seek these out.
Also, on the sample policy that I am working off of, I noticed that to qualify for a small farm, it states that the farm has to have less than $500,000 in assets? Is that right? I know for small businesses to qualify they have to have less than $1,000,000 in gross revenue, but why does it switch to assets for a small farm. I have researched the exam manuals and other threads and sample policies and no where do I see that in order to qualify a farm has to be less than $500,000. What I do see is that the loan to the small farm has to be less than $500,000. Does anyone know of such an asset test to be considered a small farm for CRA?
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#2118740 - 02/17/17 06:14 PM Re: Small Farm Loans-2 policy questions Bec
RR Jen Offline
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I think your sample policy has a typo. From the CRA Data Collection Guide:

Small farm loans are
defined as those whose original
amounts are $500,000 or less and
were reported as either “Loans to
finance agricultural production and
other loans to farmers” or “Loans
secured by farmland.”
It is the original amount of a
loan, not the annual revenue of a
business or farm, that determines
the classification of a loan as a small
business or small farm loan.

I would not leave them out of policy, because if you make 1 you are required to report it.
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#2118756 - 02/17/17 06:58 PM Re: Small Farm Loans-2 policy questions Bec
Bec Offline
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Bec
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The Great White North
That is what I have pulled from every other source that I have looked at beside the one sample policy. So it can be a farm of any size as long as the note amount is $500,000 or less.

Is the small business having gross annual revenues of $1,000,000 or less a qualification for a small business loan or is it strictly the note amount being $1,000,000 or less in these cases. From what I am reading, it appears that in order to qualify as a small business loan both of those have to be true? OR am I off the mark there as well?
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#2118764 - 02/17/17 07:11 PM Re: Small Farm Loans-2 policy questions Bec
RR Jen Offline
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Report any loan with an applicable call code and a loan amount under the threshold ($1 million on businesses and $500,000 on farms). THEN you report the gross annual revenue amount on those loans, it's a reportable field but not a determining factor. Asset size doesn't come into play anywhere.

That help?
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#2118766 - 02/17/17 07:13 PM Re: Small Farm Loans-2 policy questions Bec
RR Jen Offline
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And by report the gross annual revenue "amount" I mean a 1, 2, or 3 as defined in the instructions...not the actual dollar amount. smile
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#2118786 - 02/17/17 08:09 PM Re: Small Farm Loans-2 policy questions Bec
Bec Offline
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Bec
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The Great White North
Very helpful. Thank you! smile
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#2118787 - 02/17/17 08:12 PM Re: Small Farm Loans-2 policy questions Bec
RR Jen Offline
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RR Jen
Joined: May 2003
Posts: 3,760
Running and riding everywhere ...
You're welcome and good luck!
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