Are credit cards issued to small businesses considered “small business loans”?
A4. Credit cards issued to a small business or to individuals to be used, with the institution’s knowledge, as business accounts are small business loans if they meet the definitional requirements in the Call Report or TFR instructions. § 345.12(x) Wholesale institution § 345.12(x)–1: What factors will the agencies consider in determining whether an institution is in the business of extending home mortgage, small business, small farm, or consumer loans to retail customers? A1. The agencies will consider whether: The institution holds itself out to the retail public as providing such loans; and The institution’s revenues from extending such loans are significant when compared to its overall operations, including off-balance sheet activities. A wholesale institution may make some retail loans without losing its wholesale designation as described above in Q&A § 345.12(n)–2. § 345.21–Performance tests, standards, and ratings, in general § 345.21(a) Performance tests and standards § 345.
