Not all small farm and small business loans qualify for Community Development recognition. They must meet the "economic development" definition which means job creation, preservation or improvement primarily for LMI persons.
We always recommend that an ISB collect and report their CRA loan data on a voluntary basis. If you are going to take your CRA responsibilities seriously you must be collecting the data and monitoring it. So why not report it? - especially if it preserves your elective to be examined under the Large Bank standards.
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