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?