If I have a loan that is made to Habitat to puchase a warehouse for storage, can I report it also as a small business loan? Thanks.

Assuming your loan meets all the parameters for a small business loan, you can't report it otherwise. Were you trying to report this as a CD loan? You can't if this is a small business loan. If I am missing something here it will be corrected shortly.

What is the loan amount and collateral?

The loan amount is 24,000 and it is unsecured.

Sorry to say this is small business, how will it be reported on your call? You can't have it both ways. Now that isn't to say you can't discuss it with examiners at the appropriate time for additional consideration.

see the ongoing discussion on "CD for non-profit", if you are not reporting as small business on the call, you may still be able to report as a CD loan, if that was the original question.

The CRA definitions are very convoluted. You have to watch the exceptions, the exceptions to the exceptions and the exceptions that get picked up in the other categories. I finally color coded my RC-C with highlighter to try to figure it all out.

I also highly recommend that you print out the whole RC-C, Section 1 rather than just the addenda that comes with the CRA Guide. There are a few nuances that you lose with just the addenda.

I'm with Rie A that RC-C is required reading, however I disagree with Pale Rider that this loan must be reported as a small business loan.

If this loan is to purchase a warehouse, but is NOT secured by the warehouse, then it should not be call coded under 1e (Secured by nonfarm nonresidential properties). Assuming we're talking about Habitat for Humanity, and it's a non-profit organization, it would be call coded as 9 (other loans). This call code is not one of the CRA small busniess call codes, so assuming the loan has a community development purpose, I don't see any reason why it would not be reported as a community development loan.

As always, if there's a flaw in my logic, someone please correct me.

Unsecured loans to non-profits are not reportable as small business loans. But they do present an excellent opportunity for Community development credit. I have seen unsecured lines of credit that are renewed annually reported and recognized as community development loans each and every year they are renewed. Just make sure you properly document the CD qualifications. Documentation is absolutely critical to withstanding the scrutiny of your examiner.

Yep, it would be on my report as a CD loan. Actually I have one just like it.

As Len noted, lines of credit are even better. I have one to an Economic Development Corporation that gets renewed every year so I get to count it each and every year! This has been blessed by my regulator.

Question:

When the loan is renewed every year is a new note signed for it to be reportable?

Can you still report it if the line renews but a new note is not signed??

We have some loans that are not getting reported every year upon their renewal because a new note is not signed (including both community development loans and small business loans).

Quick answer, no, you do not need a new note signed. I hate to just give quick answers without the reference to go with it but don't seem to be able to put my hands on it right at this moment.

Something about it must require a "loan decision" for the renewal, it can't just be automatic. If I come across it I will post it later.

A small business loan renewed each year can be reported each calendar year. If the loan is renewed in the same calendar year, the loan can be reported a second time in that calendar year, but only the amount of any new money can be reported. Also the second loan must have a distinct and different ID number in order for it to be reportable. Duplicate ID numbers are not acceptable for reporting in the same calendar year, but the same ID number can be used in different calendar years.