Posted By: HMDA CRA Gal
Partner Loans - Small Business Reportable? - 05/06/20 08:27 PM
Trying to determine if some loans are CRA reportable and would love some input from the CRA gurus out there!
We are doing new loans to partners of an entity. The loans are to individual partners of the firm for the purpose of purchasing stock or funding their capital accounts. The loans are unsecured. Would these loans be reportable as small business? I'm not sure if these fall under Call Report 4- Commercial and Industrial loans or 9. Other Loans. From the call report instructions:
Include loans of the types listed below as commercial and industrial loans. These
descriptions may overlap and are not all inclusive.
(1) Loans for commercial, industrial, and professional purposes to:
(a) mining, oil- and gas-producing, and quarrying companies;
(b) manufacturing companies of all kinds, including those which process agricultural
commodities;
(c) construction companies;
(d) transportation and communications companies and public utilities;
(e) wholesale and retail trade enterprises and other dealers in commodities;
(f) cooperative associations including farmers' cooperatives;
(g) service enterprises such as hotels, motels, laundries, automotive service stations,
and nursing homes and hospitals operated for profit;
(h) insurance agents; and
(i) practitioners of law, medicine, and public accounting.
(2) Loans for the purpose of financing capital expenditures and current operations.
Exclude from commercial and industrial loans:
(1) Loans secured by real estate, even if for commercial and industrial purposes (report in
Schedule RC-C, part I, item 1).
(2) Loans to depository institutions (report in Schedule RC-C, part I, item 2).
(3) Loans to nondepository financial institutions such as real estate investment trusts,
mortgage companies, and insurance companies (report as all other loans in
Schedule RC-C, part I, item 9).
(4) Loans for the purpose of purchasing or carrying securities (report in Schedule RC-C,
part I, item 9).
Would these loans fall under call report 4 or 9? My initial thought was 9 Other Loans, but I am struggling with this one. Any thoughts would be greatly appreciated!
We are doing new loans to partners of an entity. The loans are to individual partners of the firm for the purpose of purchasing stock or funding their capital accounts. The loans are unsecured. Would these loans be reportable as small business? I'm not sure if these fall under Call Report 4- Commercial and Industrial loans or 9. Other Loans. From the call report instructions:
Include loans of the types listed below as commercial and industrial loans. These
descriptions may overlap and are not all inclusive.
(1) Loans for commercial, industrial, and professional purposes to:
(a) mining, oil- and gas-producing, and quarrying companies;
(b) manufacturing companies of all kinds, including those which process agricultural
commodities;
(c) construction companies;
(d) transportation and communications companies and public utilities;
(e) wholesale and retail trade enterprises and other dealers in commodities;
(f) cooperative associations including farmers' cooperatives;
(g) service enterprises such as hotels, motels, laundries, automotive service stations,
and nursing homes and hospitals operated for profit;
(h) insurance agents; and
(i) practitioners of law, medicine, and public accounting.
(2) Loans for the purpose of financing capital expenditures and current operations.
Exclude from commercial and industrial loans:
(1) Loans secured by real estate, even if for commercial and industrial purposes (report in
Schedule RC-C, part I, item 1).
(2) Loans to depository institutions (report in Schedule RC-C, part I, item 2).
(3) Loans to nondepository financial institutions such as real estate investment trusts,
mortgage companies, and insurance companies (report as all other loans in
Schedule RC-C, part I, item 9).
(4) Loans for the purpose of purchasing or carrying securities (report in Schedule RC-C,
part I, item 9).
Would these loans fall under call report 4 or 9? My initial thought was 9 Other Loans, but I am struggling with this one. Any thoughts would be greatly appreciated!