I've been very busy and haven't been back to BOL for the last week or so, but someone contacted me about this issue.
Letters of credit are definitely excluded as small business loans, but lines of credit are included. It seems crazy that a line of credit would be eligible while a letter of credit would not be, but that's the case. In the Q&A's it is stated that a bank can present letters of credit commitments for consideration during a CRA exam (but they aren't reported).
Now if you establish a "line of credit" and a letter of credit is issued under that line of credit you wouldn't report the letter of credit, but you would report the line of credit. Don't forget if you issue a line of credit commitment, reporting the letter of credit would be redundant - it would be reporting the same credit twice.
So report the line of credit but don't report the letter of credit. The more I think about it Mel, you may have discovered a way to get credit for letters of credit by extending a line of credit and then issuing a letter of credit pursuant to the line! You're brilliant!
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