The original post indicated the LOC is greater than $1MM so it would not be reported as a small business loan on the CRA LR. Since it cannot be reported on the LR, it is reportable as a Community Development loan IF it qualifies under the definitions of Community Development which generally boil down to - Affordable Housing, Community Services, Revitalization/Stabilization, and Economic Development.
Last edited by Princess Romeo; 08/21/18 01:15 AM.
If the business exceeds the size eligibility for SBA, then it's a pretty high bar to have the an Operating Expense LOC qualify under the "Revitalize and Stabilize" prong for Community Development.
However, if the business meets the size eligibility for SBA and you can document that the loan helps the business create, retain or improve jobs in LMI areas OR for LMI individuals, then it meets the definition under the "Economic Development" prong for Community Development.
Regulations are a poor substitute for ethics.