Jump to Content
ABA: The American Bankers Association
Skip Section Navigation

May business credit cards issued to nonprofit organizations be reported under the Community Reinvestment Act as small business loans? May they be reported as community development loans?

May business credit cards that are issued to nonprofit organizations be reported under the Community Reinvestment Act (CRA) as small business loans? If not, may they be reported as community development loans?

It is possible that business credit cards may be reported as small business loans. Section §_.12(v)-4 in the July 2016 updates to CRA questions and answers provides: “Credit cards issued to a small business or to individuals to be used . . . as business accounts are small business loans if they meet the definitional requirements in the Call Report instructions.”

To be reported as community development loans, they generally must not have been reported as small business loans and have a primary purpose of community development. For example, §_.12(h)-1 of the same guidance above provides as an example of a community development loan, one to “not-for-profit organizations serving primarily low- and moderate-income housing or other community development needs.” (April 2020)

Compliance Hotline

Have a compliance-related question? We're here to help. Members, reach us by phone or email.