Our bank will cross the ISB threshold for the second time at the end of 2017 so we will officially be an ISB. FRB is coming in June 2018 so I have to go back over everything we've done since last exam.
Just want to confirm my understanding:
- Loans that went on HMDA LAR cannot be claimed for CD unless they are five unit multi family or more
- Loans of $1M or under to businesses MUST be claimed as small business loans -- I do not have the option to choose whether or not to claim as CD
- Same question on ag loans, $500,000 or under
- I cannot "double dip" on SBA guaranteed loans or FSA guaranteed loans (they are either small business/farm or CD but cannot be both
- Small business or small farm loans do not count for CD unless they create jobs for low/mod individuals
Any other tips to help me sort out our loans would be greatly appreciated!