[GabyHolloway]

Are letters of credit reportable as small business loans for CRA purposes? I’m finding different answers….

thank you

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[pparks]

Because they are NOT reported on the RC-C (Loans and Leases) section of the bank’s Call Report (No, they are not 4a’s), they are not reported on the CRA LR. Although, they can be presented separately to examiners for CRA credit consideration. Letters of Credit are to be reported on another section of the Call Report (I believe the RC-L). Now if a loan was ever created to fulfill the promise represented by the Letter of Credit, then that loan may be reportable itself…but once again, while a Letter of Credit is a legal document, it is not itself a loan, regardless of the process and coding a bank decides to create for it. In which case, have your filters ready.

[Author]

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