Q: What types of loans to nonprofits are not reportable?
This issue is addressed in question ___.12(v)-1 of the March 11, 2010 Interagency Questions and Answers Regarding CRA (Q&A), which are available at http://bit.ly/CRA-qa
. (Question __.12(v)-1 appears on page 11653 of the Federal Register notice
.) In general, a loan to a nonprofit organization secured by nonfarm, nonresidential property for business or farm purposes is:
A small business loan if it is a business loan with an original loan amount of $1 million or less, or
A small farm loan if it is a farm loan with an original amount of $500,000 or less.
In addition, as explained in the Consolidated Reports of Condition and Income (Call Report) Instructions for Schedule RC-C, a loan to a nonprofit organization that is collateralized by an oil or mining production payment would be considered a small business loan; however, all other loans to nonprofit organizations would generally be classified under Item 9 (Other Loans) and, therefore, would not be reportable as small business or small farm loans. Loans to nonprofit organizations that are not small business or small farm loans for Call Report and Thrift Financial Report (TFR) purposes may be considered as community development loans if they meet the regulatory definition of community development.
Users are advised that references to CRA Interagency Q&As may have been updated since that webinar.