Can you explain what is considered a nonresidential loan for CRA purposes? Example that I have is a: Commercial loan of $550,000.00 for working capital, secured by a mortgage on 3 separate residential investment properties and an assignment of rents. Does nonresidential mean primary residence only?

Is this reportable as a small buiness loan? There are no affordable houses included.

Follow the call report guidelines for loans that are reported on Schedule RC-C1 (loans and leases) on lines 1(e)1 and 1(e)2 (secured by commercial real estate) and 4a (business purpose loans not secured by real estate.

Those are the only line items that qualify as small business for CRA; those lines carry over to schedule RC-C2 (small business/small farm).

You should also look at the descriptions of the classifications for the loans secured by residential real estate.

Loans primarily secured by residential real estate (owner occupied or non-owner occupied) cannot be small business loans for CRA. Also, if a loan is not primarily secured by residential real estate but is HMDA reportable it must stay in HMDA (subject to some special rules for ISBs). Otherwise the loans would be double counted for CRA as HMDA is included in the exam.

There is a training webinar available in the BOL store on coding small business and small farm loans that I did in October 2012 that covers the classification rules.