Is loan term a determining factor in whether a small business loan meets the definition for CRA reporting? I found where it states that land development loans with a term of 60 months or less are not considered small business. Is the term of 60 months or less just an exclusion for land development or ALL small business loans?

Example: We have a loan secured by commercial real estate with a term of 36 months. Is this exempt from CRA reporting because of the term?

The definition of a CRA Small Business loan is found in the Federal Call Report definitions coded 1e and 4A. I don't believe they mention anything about terms as a qualifying requirement.

If your loans do not meet these definitions, and are not coded with these Federal call codes they should not be reported as CRA Small Business Loans.

As Don points out, the key is the Call Report (or Thrift Financial Report) for determining what qualifies as a reportable small business or small farm loan. You should have in place a process to compare and reconcile what you are recognizing as CRA reportable and what your bank is classifying as small business or small farm in the Call Report. If you don't have such a process you could be in the embarassing position of reporting the loans differently which means your bank will have made a mistake on one report or the other.