Is there any reason why a Commercial ODLOC product cannot be reported on the CRA LR? What about the coming 1071 SBL LAR?

I just wanted to refresh this as I never received a response from anyone...Thanks

If it is a true line of credit supported by a note, why would you not, if it otherwise qualifies for reporting?

CRA

§ __.42 – 3: How should an institution report data on lines of credit?

A3. Institutions must collect and report data on lines of credit in the same way that they provide data on loan originations. Lines of credit are considered originated at the time the line is approved or increased; and an increase is considered a new origination. Generally, the full amount of the credit line is the amount that is considered originated.

1002.102 (n) Open-end credit transaction means an open-end credit plan as defined in Regulation Z, 12 CFR 1026.2(a)(20), but without regard to whether the credit is consumer credit, as defined in § 1026.2(a)(12), is extended by a creditor, as defined in § 1026.2(a)(17), or is extended to a consumer, as defined in § 1026.2(a)(11).

They have associated agreements (Commercial ODLOC Agreement).

"A loan agreement serves a similar purpose as a promissory note. Like a promissory note it is a contractual agreement between a lender who agrees to loan money to a borrower. However, a loan agreement is much more detailed than a promissory note."
I obtained this from a legal resource.

"Its a combined note/credit agreement like the other similar products."
I was told this by a manager over our Loan Administration area.

So in your wisdom, would you consider these to have a note?

Ask your legal counsel. If it is binding promise to lend and binding promise to repay, then it is a loan.