CRA reportable if not HMDA reporter?

Our bank is no longer a HMDA reportable bank as of 2021. Can we report a loan on the CRA LR under SB since since we are not reporting it on a HMDA LAR? Loan is secured by a 1-4 family rental property for purchase.

I'm guessing no. How is the loan being categorized for your call report? That will drive CRA small busienss reporting.

Small-business loans are defined as those whose original amounts are $1 million or less and that were reported on the institution’s Call Report or TFR as either “Loans secured by nonfarm or nonresidential real estate” or “Commercial and industrial loans.”

If it meets the call report code requirements of being non-farm/non-residential or commercial and industrial purposes, and is is for <=$1,000,000 it qualifies.

The only lending activity that gets reported under CRA is small business loans, farm loans, and community development loans. Any other activity including the elective types of consumer loans (credit cards, auto lending,, etc.,) never gets reported. What happens is if you capture that data it is retained in the "micro-data" file on your desktop. When you are about to undergo a CRA exam, you can inform the EIC that you want the exam to include certain types of loans for which you have collected activity and scrubbed and edited the data (you have to establish a basis for the examiners to trust the integrity of your data).

The regulators will evaluate your home mortgage lending "whether or not the bank is required to report under HMDA", but it will be evaluated as it would be if it had been reported. BTW, a dwelling secured loan will never be considered a small business loan if it was for the purchase, refinance or improvement of a residential property.