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#1512617 - 02/21/11 05:14 PM Small Business Loan?
BNKO Offline
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Joined: Sep 2009
Posts: 213
I've got a loan amount of $250,000 secured by a residential real estate contract. Would this be a small business loan for CRA purposes?

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CRA
#1512640 - 02/21/11 07:39 PM Re: Small Business Loan? BNKO
Checkmate
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The CRA Loan Data Collection Grid: Small Business Reportable Loans that are Residential Real Estate Secured

1. Refinance of a loan to a for-profit entity where the residence is taken as collateral as an abundance of caution. The new loan must satisfy and replace an existing loan, and both the existing and new loans must be secured by a lien an a dwelling.

2. Refinance of a loan to a nonprofit entity where a residence is taken as collateral as an abundance of caution. Same verbaige noted as above.

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#1512641 - 02/21/11 07:43 PM Re: Small Business Loan? BNKO
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
If your loan is for a small business purpose and is NOT secured by real estate (no lien has been assigned to the bank along with the contract) it does not appear to be excluded under call report instructions as a small business loan.

You should look to your purpose and review the call report instructions for small business loans.

If this loan is actually secured primarily by residential real estate it can only come in as a refi, or as a CRA Type 3.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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