A loan to be reported on our Bank's CRA Small Business report was recently questioned - internally - because the loan is to an insurance agent and there is concern about reporting a loan to a "non-depository financial institution" on the Bank's Small Business report. In this scenario, the borrower is an independent agent for a national insurance company that offers loan products however it is unclear if the agent is involved in lending.

I've reviewed Reg BB, the CRA Guide to Reporting and the Fed's (and OCC's as we are OCC) exam procedures however am not seeing a reference to any restriction on reporting Small Business loans made to "non-depository financial institutions".

Further, unless I've missed something in the Call Report instructions, I believe the loan to be correctly reported as a Small Business loan based on the loan being unsecured and extended to a for-profit entity (Call Code 4A which actually lists insurance agents as an example).

Thoughts on the "non-depository institution topic" as well as reporting CRA Small Business loans made to insurance agents - does your answer change if the insurance agent also offers loan products?

Thanks