Looking for input on community development loan reporting for commercial loans with a community development purpose that are $1 million or less at origination. The CRA QnA indicates "retail institutions must report loans that meet the definition of ‘‘home mortgage loan,’’ ‘‘small business loan,’’ or ‘‘small farm loan’’ only in those respective categories even if they also meet the definition of ‘‘community development loan.’’

In reading other bank PE's, I find that CD credit is being given, at times, for loans $1MM or less with a CD purpose. Does this match your experience? Your input is appreciated! Please include your regulator with your response.

Often times the examiners will not give you credit for the loan but will mention it in the PE.

You must code them for HMDA, small business or small farm if they qualify. However, it is possible to have a loan not qualify for any of those categories, be a CD and still be less than $1 million.

For example, an unsecured loan to a non-profit with a CD purpose, we have at least two of these under $500,000 each.

If they are reportable is one of those categories, you must report them as such and cannot 'double' report them separately as a CD loan. What you can do, as bubs alluded to, is mark them and then point them out to the examiners when they are in house - this often gets you some brownie points. "See, we have these great loans, but they had to be reported under X category." I have occaisonally found under $1MM loans with CD purposes that were exempt from those other reporting categories for various reasons, and you better believe I report those as CD!

Rie A, why wouldn't your example loan (unsecured loan to a nonprofit with a CD purpose) be coded as small business since it is less than $1 million?

Thank you for your input!

Small business loans must fall on the Call Report in either 4a or 1e AND be $1MM or under. An unsecured loan to a non-profit would be a 9b (I think - without looking it up).

Becca is right, Unsecured non-profit loans would be given a 9B call code. This would not be HMDA or CRA Small Bus/Farm, so given the loan has a qualified primary purpose of community development that you can substantiate to examiners, you could report it as Community Development, even if it has an original balance of less than or equal to 1 Mil. Bottom line, any call code that falls outside the HMDA/CRA reportable codes can be reported for Community Development regardless of the amount of the loan.

The Federal Reserve Bank of Dallas compiled CRA Loan Data Collection Grid This can come in handy when you don't have time to look up the call report codes.

Thank you to everyone for your input! One more question. Does the same principle apply with the TFR. We are an OTS regulated institution and I've been trying to discern the TFR instructions for this type of loan, but they are as clear as mud in my opinion. Your feedback is appreciated!

Make sure you have the most recent updated version of the data guide. The regulators instituted a special carve-out for ONLY intermediate small banks in which banks can identify, say, business loans less than $1 million that also meet the definition of CD and have them actually considered under the CD test.

We are a large bank and we did not receive credit for loans less than $1MM - we did track them and provided them to the examiners but weren't given credit.

Loans that are included in Schedule SB of the TFR for the period in question are those eligible for Small Business and Small Farm reporting. The dollar thresholds and categories are the same as the call report categories. Looking at the other sections that are referenced for this Schedule will show you that the categories are the same as for the Call Report (non-residential real estate, etc.)