Is there a way to track community development loans when they are not coded as such on the loan system? We have a checklist that the loan officers complete, but that just doesn't seem reliable enough.

Not sure if this is addressing your question, however here is my 1 cent.

Mapping your loans to the call report is your best option. The loans outside the small business reportable loans should be under scrutiny for possible CDL. However, loans can be inappropriately reported (based on erroneous collateral or purpose) on the call report.

In addition to our lenders having a field to indicate if a loan is a CDL, we also have a few other indicators that help us identify a CDL. One is a field that indicates if it is a loan to a political subdivision (municipality, county, etc.) or a non-profit organization. If that is the case, we exclude those that are “owner-occupied” secured by real estate (small business reportable if < $1 million) then we have a pool of loans to review to see if they possibly have a community development purpose (e.g. – line of credit to a free clinic, vehicle loan to a food bank, etc.).

We perform queries based on census tract income level (< 80% of MSA Median Family Income), or loan location in a distressed or underserved middle-income census tract or in an enterprise/empowerment zone. Since we cannot include land development loans in our small business reporting, it is quite possible that one could be located in a LMI or a distressed or underserved middle-income census tract that has a community development purpose (e.g. – purpose to build a grocer, pharmacy, community center, etc.).

Another query we perform is loans in the amount > $1 million. Again, we are looking for loan location and whether it has a community development purpose.