Interagency Q&A .42(a) – 1: Must institutions collect and report data on all commercial loans of $1 million or less at origination?

Compliance > Regulation BB - CRA
Q:  § __.42(a) – 1: Must institutions collect and report data on all commercial loans of $1 million or less at origination?
 
A:  No.  Institutions that are not exempt from data collection and reporting are required to collect and report only those commercial loans that they capture in Call Report Schedule RC-C, Part II.  Small business loans are defined as those whose original amounts are $1 million or less and that were reported as either “Loans secured by nonfarm or nonresidential real estate” or “Commercial and industrial loans” in Call Report Schedule RC-C, Part I.
 
 
 
This Interagency Q&A, and others, was released in July 2016.  The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately.  They may be found here:  http://www.ffiec.gov/cra/qnadoc.htm
 
 

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