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Construction CRA Reportable as Other Business Loan

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I'm new at CRA and while I'm sure a construction loan isn't HMDA reportable and wouldn't be CRA reportable as Small Business (collateral is residential property). Is it possible a construction loan could be CRA reportable as Other Business Loan? My borrower is building homes for business purpose, secured by the residential property being built.

Construction loans will never be small business loans for CRA (type 1 or type 3). A general purpose working capital loan to a builder could end up in small business if amount is $1 million or less.

Otherwise, construction loans come into play if they can qualify for community development credit.

First published on 8/6/12

First published on 08/06/2012

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