I'm new to this so forgive my ignorance, If you have a loan that qualifies as small business and it is to provide a line of credit to be used for working capital but is secured by commercial real estate, would you code it by it's true purpose (business line of credit) or as commercial real estate (CALL code)?

This will be reported on line 1E of the Call Report as commercial real estate secured. We use a 1E as our Call Report Code - yours may be different. As far as CRA, it is coded as 01 - small business loan under "Type of Loan" for submission.

All CRA Small Business loans MUST meet the definition of 1e and 4a on the call report. and should always have one of these call codes assigned to the loan.

Other than these two call codes, loans reported a CRA Small Business loans should have no other call code.

The real question is on my register the codes to choose from are ag loan, ag line of credit, com'l RE, Bus line of credit, bus loan and busi w/ residential RE...so the actual purpose of the loan was just a business line of credit but it was secured by residential real estate. Am I to enter the loan on my register as what the loan was entered on the CALL report (secured by non farm/non residential properties - Com'l RE)or what the true purpose of the loan was(business line of credit)?

Your facts are confusing. In your first post you mentioned the loan was secured by commercial real estate. But in this latest post you indicate it is secured by residential re. This is a critical distinction under CRA. If it is directly secured by residential re, then it is not reportable as a small business loan. If it is indirectly secured (e.g., the residential re secures a personal guarantee of the loan) then there is some debate about whether it is reportable. I have spoken to high level people in the FDIC and the OCC about this and they have told me if the residential re indirectly secures the loan (by virtue of the guarantee) then the loan is reportable under CRA if it has the other elements of a small business loan. I also have been told that this issue may be explicitly addressed in a new set of Q&A's to be issued by the FFIEC before year end.

Sorry Len. The loan was secured by com'l RE. My fingers were typing faster than my mind was thinking

CRA coding only offers three choices for business/commercial loans 1 - small business loan, 2 - Ag loan, 3 - small business secured by residential real estate. 1&2 are reportable, 3 is optional for examination.
If you have a true commercial line of credit and it is under $1million and not secured by residential RE, then it is a 1.

KC I may be reading your Post incorrectly and apologize if I am.

Here are your CRA Loan Type Codes

1 = Small Business - Should meet definitions of Fed Call Code 1E and 4a. Exception -If SBA Guaranteed and has SFR as collateral,OK to report as CRA Small Business Loan Type Code 1. Origination amount $1,000,000 or less

2= Small Farm Loan - Should meet definition of Fed call codes 1B and 3. Originating $500,000 or less

3 = Other Lines and Loans for Small Business Purposes. Use if Small business loan but collateralized by SFR. Not reported in annual submission but you can ask examiners consideration as additional CRA credit at exam time. Origination amount must be 1 million or less.

Isn't that what I said?

Yep that's what you said

It was the 3 choices for business/commercial loans and I was reading to much into it. I didn't want to confuse that you can code other business and commercial loans with other call codes but only these three fed call code contain the definations for loans that qualify as cra loan types.