The Guide to CRA states that for "loans secured by Nonfarm Residential Real Estate used to finance small business must be reported as "loans secured by real estate"......". Does "residential real estate" include vacant residential land/lots?

thanks,

No. Only those non farm non res properties reported on lines 1e1 and 1e2 of Schedule RC-C1 of the Call Report. Land loans are on another line.

We are collecting other data for examination purposes and it states to report loans secured by nonfarm residential real estate under "Other Secured Lines/Loans for purposes of Small Business" for examiner evaluation.

We are not sure whether to include the vacant residential lots under this category.

thanks,

I answered re non farm non residential. Sorry.

Business purpose Non farm non-HMDA residential goes in Type 3 if $1million or less.

Is it okay to include residential vacant lot loans under Type 3 since these are not HMDA and are for business purpose?

thanks

I have never done that. Land loans are always 9.

Residential real estate is for completed properties.

Okay.....thank you very much.

Is a construction only loan (no permanent financing) of a single family residence be considered a "completed property" to report it under CRA type 3? or is it considered as vacant property since the home is being constructed and reported under CRA type 9.

thanks,

Construction loans are type 9. They would be on your call report under construction loans. Review the information in the Call Report instructions for Item 1a of Schedule RC-C1.

Construction, land development, and other land loans. Report in the appropriate subitem
(on the FFIEC 041, in column B; on the FFIEC 031, in columns A and B for large institutions
and highly complex institutions – as defined for assessment purposes – with foreign offices,
and in column B for all other institutions with foreign offices) loans secured by real estate
made to finance (a) land development (i.e., the process of improving land – laying sewers,
water pipes, etc.) preparatory to erecting new structures or (b) the on-site construction of
industrial, commercial, residential, or farm buildings. For purposes of this item, "construction"
includes not only construction of new structures, but also additions or alterations to existing
structures and the demolition of existing structures to make way for new structures.

https://www.fdic.gov/regulations/resources/call/crinst/2015-06/615RC-C1_063015.pdf

Thank you very much.

Is an apartment building considered "residential real estate" to report it under CRA - type 3 (loans secured by nonfarm residential real estate under "Other Secured Lines/Loans for purposes of Small Business")?

We have a loan renewal secured by apartments. It's not a community development purpose loan and not HMDA reportable. Can we report it under CRA type 3 or is it a type 9?

Thank You

Why is it not HMDA reportable?

It's not HMDA because it's a renewal with no new money advanced. The existing debt is not being replaced.

Can we report a loan secured by a multifamily dwelling under CRA type 3 (loans secured by nonfarm residential real estate under "Other Secured Lines/Loans for purposes of Small Business")? It does not meet Community development purpose and is not HMDA. Or should we place under type 9-Other?

Thank You