Reportability of City/Municipality Loans

Are non real estate loans made to cities and municipalities exempt from CRA reporting?

The only loans subject to CRA are loans reported on the Call Report items 1e (nonfarm, nonresidential real estate) and 4a (C&I) loans. If your bank engages in substantial lending activity of another type such as automobile lending then examiners may include that in the PE. Also, if you are an ISB or larger you would report community development loans. Loans to municipalities are not included in the items I cited above. However, in rare circumstances, they might be considered as CD loans (such as revitalization of low or moderate-income communities.