Reaching out for some clarification please.
Example:
January 2018 Small Business loan origination for $1.5 million – not reportable
Same borrower; same loan gets an increase March 2018 for $350,000
Can we report the $350,000 as an origination?
Then if we then make a subsequent renewal in the same year, May 2018, we make an increase of $250,000 more can we report both $350,000 and the $250,000?

Then let’s say we do another renewal in September 2018 for $400,000 could we report that amount and not the $250,000 thus just reporting the larger of the renewals since you can only report one per year?

If the original loan was greater than 1MM and lacked a community development purpose, any increases would also not be reportable under the guidance of call report instructions. If you had a loan that was originally less than 1MM and an increase were to put the loan over 1MM you would report the increase(s) in your "Other Loan Data" submission. Now if the loan did have a CD Purpose, you would aggregate the increases at the end of the calendar year into one record and report that.

Hi, Spidergirl,

I just asked my regulator (FDIC) this same question as it pertains to loans (not Lines of Credit). Their response is that you would NOT report the March increase because the original loan is over $1MM. The same would appear to go for the $250,000 then as well.

If, however, you have a loan of $600K in Jan of 2018 and an increase of $500,000 in May of 2018, you would report both loans on the CRA LAR because you can only report an increase if the original amount has already been reported one time that year. (If the original loan is over $1MM, it would not have been reported, therefore, the increase cannot be reported.) I would not report the $500K as "other loan data" as mrogersfib suggested as I believe they are referring to situations where increases to Lines of Credit put the total loan over $1MM.

I hope this helps!