Skip to content
BOL Conferences
Thread Options
#2236276 - 05/06/20 08:27 PM Partner Loans - Small Business Reportable?
HMDA CRA Gal Offline
Junior Member
Joined: Sep 2009
Posts: 43
Trying to determine if some loans are CRA reportable and would love some input from the CRA gurus out there!

We are doing new loans to partners of an entity. The loans are to individual partners of the firm for the purpose of purchasing stock or funding their capital accounts. The loans are unsecured. Would these loans be reportable as small business? I'm not sure if these fall under Call Report 4- Commercial and Industrial loans or 9. Other Loans. From the call report instructions:

Include loans of the types listed below as commercial and industrial loans. These
descriptions may overlap and are not all inclusive.
(1) Loans for commercial, industrial, and professional purposes to:
(a) mining, oil- and gas-producing, and quarrying companies;
(b) manufacturing companies of all kinds, including those which process agricultural
commodities;
(c) construction companies;
(d) transportation and communications companies and public utilities;
(e) wholesale and retail trade enterprises and other dealers in commodities;
(f) cooperative associations including farmers' cooperatives;
(g) service enterprises such as hotels, motels, laundries, automotive service stations,
and nursing homes and hospitals operated for profit;
(h) insurance agents; and
(i) practitioners of law, medicine, and public accounting.

(2) Loans for the purpose of financing capital expenditures and current operations.

Exclude from commercial and industrial loans:

(1) Loans secured by real estate, even if for commercial and industrial purposes (report in
Schedule RC-C, part I, item 1).
(2) Loans to depository institutions (report in Schedule RC-C, part I, item 2).
(3) Loans to nondepository financial institutions such as real estate investment trusts,
mortgage companies, and insurance companies (report as all other loans in
Schedule RC-C, part I, item 9).
(4) Loans for the purpose of purchasing or carrying securities (report in Schedule RC-C,
part I, item 9).


Would these loans fall under call report 4 or 9? My initial thought was 9 Other Loans, but I am struggling with this one. Any thoughts would be greatly appreciated!

Return to Top
CRA
#2241111 - 08/15/20 03:53 PM Re: Partner Loans - Small Business Reportable? HMDA CRA Gal
InFairness, CRCM Offline
Platinum Poster
InFairness, CRCM
Joined: Nov 2010
Posts: 919
USA
Based on this bullet, I'd classify them as 9 Other Loans.

(4) Loans for the purpose of purchasing or carrying securities (report in Schedule RC-C,
part I, item 9).
_________________________
Opinions are strictly my own, and have nothing to do with my employer.

Return to Top
#2279819 - 01/13/23 04:25 PM Re: Partner Loans - Small Business Reportable? HMDA CRA Gal
HMDA CRA Gal Offline
Junior Member
Joined: Sep 2009
Posts: 43
Hello! This question has come up again. These are unsecured loans to individual partners of an entity (e.g. Deloitte) for the purpose of funding their capital account at the firm (a requirement as part of the capital loan program). Should these be classified as 4 - Commercial & Industrial, and therefore reported as Small Business? Or should they be classified as 9-Other Loans? Thoughts are greatly appreciated. Thanks!

Return to Top
#2280274 - 01/25/23 04:52 PM Re: Partner Loans - Small Business Reportable? HMDA CRA Gal
HMDA CRA Gal Offline
Junior Member
Joined: Sep 2009
Posts: 43
Bump

Return to Top
#2280276 - 01/25/23 05:57 PM Re: Partner Loans - Small Business Reportable? HMDA CRA Gal
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Sounds like personal loans to me to meet their personal funding responsibilities.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top