Hello all, need a little help. Been searching online for confirmation and have not been able to find a definite answer.

For CRA reporting purposes (but not Call Report), trying to determine if investor CRE (smaller under 20 unit multi-fam properties and smaller retail or office CRE) is considered to be a SMALL BUSINESS loan. Loan amount is > $1MM (but under $3MM) and REV size is < $1MM.

Any insight would be great and link to regulator (OCC or FDIC) would be awesome.

CRA reporting is directly related to how it is classified for the Call Report, so you can't really separate the two. Anything under $1 million and C&I or CRE on your Call Report is Small Business for CRA. Multi-family is not a small business loan (but potentially HMDA), the other stuff seems like CRE, but you'd have to look at how you report on the call report.

"Small business loans are defined as those whose original amounts are $1 million or less and that were reported on the institution’s Call Report as either “Loans secured by nonfarm or nonresidential real estate” or “Commercial and industrial loans.” Small farm loans are defined as those whose original amounts are $500,000 or less and were reported as either “Loans to finance agricultural production and other loans to farmers” or “Loans secured by farmland.”"

https://www.ffiec.gov/cra/pdf/2015_CRA_Guide.pdf

Inherent_Risk is correct. Ideally, you should be able to run a report of your loans and sort them out by call code to identify your CRA reportable loans.

But do consider that it is possible that the wrong call code may be assigned. I have worked for several banks in the past where this happened due to the lack of training for the employees responsible for assigning the call codes at the time a loan was boarded. An error that I noted in the past was multi-family loans (call code 1D) being classified as CRE (call code 1E) because the loan was originated by a commercial business unit.

Reconciling your CRA small business loans to the Call Report codes is a highly recommended best practice. It's not infallible as TTC points out, but it's better to have 2 wrongs rather than 1 right and 1 wrong because it looks like the left hand doesn't know what the right hand is doing. If discrepancies are discovered during the process of reconciliation and it should be determined which code is correct and then making the correction. Doing that will impress examiners that you are doing your best to assure the integrity of the CRA data.