§__.42(c)(2) – 3
Q: Are commercial and consumer leases considered loans for purposes of CRA data collection?
A3. Commercial and consumer leases are not considered small business or small farm loans or consumer loans for purposes of the data collection requirements in 12 CFR .42(a) & (c)(1). However, if an institution wishes to collect and maintain data about leases, the institution may provide this data to examiners as “other loan data” under 12 CFR §__.42(c)(2) for consideration under the lending test.
Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016