Just checking to see if everyone is reporting the PPP loans to farms as a SF loan. While they aren't technically for crop production I am assuming that the loan is helping pay for things that are essential to farming like paying wages and rents.

Thoughts?

We are holding off for guidance. Reporting PPPs could skew peer comparisons significantly, where some institutions didn't participate or limited their participation.

We coded PPP separate from our other commercial loans, so we can pull a report and bulk upload them into our CRA reporting software if we are told to report them.

Wouldn't those possibly fit the 3(4) or 3(6) instructions for what to report as a small farm?

3
Loans to finance agricultural production and other loans to farmers. Report loans for the purpose
of financing agricultural production. Include such loans whether secured (other than those that
meet the definition of a “loan secured by real estate”) or unsecured and whether made to farm and
ranch owners and operators (including tenants) or to nonfarmers. All other loans to farmers, other
than those excluded below, should also be reported in this item.

Include as loans to finance agricultural production and other loans to farmers:

(1) Loans and advances made for the purpose of financing agricultural production, including the
growing and storing of crops, the marketing or carrying of agricultural products by the growers
thereof, and the breeding, raising, fattening, or marketing of livestock.

(2) Loans and advances made for the purpose of financing fisheries and forestries, including loans
to commercial fishermen.

(3) Agricultural notes and other notes of farmers that the bank has discounted for, or purchased
from, merchants and dealers, either with or without recourse to the seller.

(4) Loans to farmers that are guaranteed by the Farmers Home Administration (FmHA) or by the Small
Business Administration (SBA) and that are extended, serviced, and collected by a party other than
the FmHA or SBA. Include SBA “Guaranteed Interest Certificates,” which represent a beneficial
interest in the entire SBA-guaranteed portion of an individual loan, provided the loan is for the
financing of agricultural production or other lending to farmers. (Exclude SBA “Guaranteed Loan
Pool Certificates,” which represent an undivided interest in a pool of SBA-guaranteed portions of
loans. SBA “Guaranteed Loan Pool Certificates” should be reported as securities in Schedule RC-B,
item 2, or, if held for trading, in Schedule RC, item 5.)

(5) Loans and advances to farmers for purchases of farm machinery, equipment, and implements.

(6) Loans and advances to farmers for all other purposes associated with the maintenance or
operations of the farm, including purchases of private passenger automobiles and
il consumer goods and provisions for the living expenses of farmers or ranchers
and their families.

Has anyone heard any more guidance on this? Right now all of our PPP loans are coded the same but that also inclues the handful of PPP farm loans we have. Just trying to figure out if I should be coding them differently.

And probably a stupid question as this is new to me.....if loans are opened but also closed in the same exam period are they still counted on the lending test like they would be as a community development loan? Any help would be appreciated.

Because the definition of loans to farmers is so broad, PPP loans of $500,000 or less will fit into the definition of small farm loans.