I am curious to know, what position do you take when a small business corporation is extended a loan secured by a lien on the business property (real or personal) and guaranteed by the owners of the business who pledge their residential properties as security for their guarantee. Is this not reportable because of the residential property used as security for the guarantee, or is it reportable because the loan is not secured by the residential property, only the guarantee is secured by the residential property? Do you have any experience with field examiners regarding this issue? Does your bank report or not report loans like this?

The loan secured by the commercial re would be reported as a 1 on the CRA LAR. Where the guarantee is residential re secured, we don't report that as residential re, it secures the guarantee, not the loan. Those commercial loans that are actually secured by residential re, whether abundance of caution or not, we report as a 3 - Other RE. Does that help?