sounds like you are capturing loans to individuals as business loans. Are they dba entities? If they are people 'doing business as" then the loans could be small business loans if they are for a business purpose. So you would record them as CRA loan type "1". But if they are being recorded as a consumer loan type (4-9) then the GAR field will be populated with a "4" indicating the loan is a consumer loan. Are you using the free FFIEC software?
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