CRA Reporting - Small Business/Small Farm Loans

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Question:

If a loan is made to a small business or small farm and secured by unimproved consumer real estate is the loan CRA reportable? I know loans secured by dwellings made for small business or small farm purposes should not be reported for CRA, but I am unsure about loans secured by unimproved consumer real estate.

Answer:

HMDA reporting supercedes CRA reporting, except for multi-family dwellings which can be reported under both. If a loan to a small business or small farm is HMDA reportable, that's where it gets reported. If it is not HMDA reportable, then it gets reported under CRA.

First published on BankersOnline.com 5/04/09