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#2247454 - 01/11/21 04:25 PM CRA Confusion
ckme Offline
100 Club
Joined: Sep 2002
Posts: 248
We are a small bank and I am trying to do some "CRA" lending analysis. I think I get the basic concept, but I am afraid that an underlying issue is creating some problems for me. We have several loans that were closed as commercial loans with call code 4- C&I, but the borrower does not have any "revenue".

An example of some that I am struggling with are:

An individual is a teacher and they borrowed to purchase supplies for their classroom.
An individual who is a musician and teaches at a school and plays for a church purchase musical equipment
A nurse purchased uniforms.

In these cased the tax returns only list the income under "wages, salaries and tips". So when an individual shows their salary, but no "business income"... how would I code their revenue?

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#2247469 - 01/11/21 05:47 PM Re: CRA Confusion ckme
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 1,982
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?
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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#2247684 - 01/14/21 07:05 PM Re: CRA Confusion ckme
Michael P Offline
Junior Member
Joined: May 2020
Posts: 27
If these are indeed COMMERCIAL loans, and fall in to the for commercial and industrial purposes call report code (doesn't really sound like it to me), they could get a revenue of 3, not known.

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#2248084 - 01/25/21 04:01 PM Re: CRA Confusion ckme
BB Offline
New Poster
Joined: Jun 2018
Posts: 16
We do not report revenue for individuals. We will never use a person’s income as revenue. Use NA.

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