We have many Dairy and Livestock loans that are set up I with the “guidance line” (ex: $1,750,000) and two separate notes for herd ($1,250,000)and feed ($500.000)that equal the guidance line. It is now my understanding the guidance line is the “Loan” and the 2 separate notes are just advances against the line.

Can I report the note for the feed ($500,000)or would the CRA guidelines look at the guidance line of $1,750,000 and make it not reportabale.

Are you sure the guidance line is a legal obligation? In many cases, a guidance line is just that. And until a note and legal obligation is created under the guidance line, there is nothing to report.

UPDATE TO MY OWN QUESTION:

Institutions must collect and
report data on lines of credit in the same
way that they provide data on loan
originations. Lines of credit are
considered originated at the time the
line is approved or increased; and an
increase is considered a new
origination. Generally, the full amount
of the credit line is the amount that is
considered originated.