Small Business Lending Survey

Board of the Governors of the Federal Reserve System

Instructions for the Preparation of

Small Business Lending Survey
Reporting Form FR 2028D
Effective December 2017

INSTRUCTIONS FOR PREPARATION OF

Small Business Lending Survey

General Instructions

tic) offices of the reporting bank (Column B of the
FFIEC 031).

Purpose of the Survey

Include:

The Federal Reserve System uses data from this survey
on United States (U.S.) chartered commercial bank
nonfarm small business lending, including costs, terms,
standards, and reasons for their changes, to assess and
analyze developments in small business credit markets.
Aggregate information on small business loans is published in a quarterly statistical release on the Federal
Reserve Bank of Kansas City’s website and through a
link on the Federal Reserve Board’s website.

• Overnight loans.

Survey Scope
This survey covers commercial and industrial (C&I)
loans made to U.S. nonfarm small businesses. The survey period covers the most recent calendar quarter.

• Construction and land development loans that are
not secured by real estate.

Exclude:
• Loans denominated in non-U.S. currencies.
• Loans made by an international division, international operations subsidiary, or Edge or Agreement
subsidiary of your institution.
• Loans made to non-U.S. addressees (business firms
domiciled outside of the fifty states of the United
States, the District of Columbia, or U.S. territories
and possessions).

For the purpose of this survey, U.S. nonfarm small
businesses are those nonfarm businesses domiciled in
the U.S. with no more than $5 million in total annual
revenues. Domiciled U.S. businesses encompass borrowers domiciled in the fifty states of the U.S., the District of Columbia, or U.S. territories and possessions,
including U.S. offices or subsidiaries of non-U.S. (foreign) businesses. For further detail, please refer to the
Glossary entry for “domicile” in the Instructions for
the quarterly condition report (FFIEC 031 & 041,
https://www.ffiec.gov/ffiec_report_forms.htm).

• Loans secured by real estate, even if for commercial
and industrial purposes.

The definition of C&I loans corresponds to that used
for Item 4 of Schedule RC-C, Part I, of the quarterly
condition report (FFIEC 031, 041, & 051). For
FFIEC 031, 041, and 051 reporters, C&I loans to U.S.
small businesses are included in Item 4.a of Schedule RC-C, Part I excluding items noted below. For
banks with foreign offices (FFIEC 031 reporters),
include all such loans that are booked at U.S. (domes-

The survey will be submitted quarterly using the Federal Reserve Bank of New York’s Statistics Survey
Application. The transmission period would begin the
first business day of the second month of each quarter
(February, May, August and November) and conclude
14 days later. Data provided on the survey would be
based on loan activity over the previous quarter. All
dollar amounts should be reported in thousands.

• Intercompany loans.
• Loans to financial institutions.
• Loans resulting from unplanned overdrafts to
deposit accounts.
• Loans held for trading purposes.

Preparation of Survey

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INSTRUCTIONS FOR PREPARATION OF

Small Business Lending Survey

Line Item Instructions
1. Check “no” if your institution does not use more
than one base rate for C&I loans to U.S. small businesses. If “no” is checked, complete question 2.
Check “yes” if your institution uses more than one
base rate for C&I loans to U.S. small businesses. If
“yes” is checked, complete question 3.
2. Enter the base rate your institution uses (i.e., prime
rate, Libor, Federal Home Loan Bank rate, U.S. Treasury rate, Proprietary rate, Other rate).
3. Indicate the three most commonly used base rates,
ranked by the total dollar value of outstanding loans to
small businesses based on each base rate as of the end
of the most recent calendar quarter.
Item 4 Outstanding term C&I loans to U.S. small
businesses broken out by fixed rate and variable rate as
of the last calendar day of the most recent calendar
quarter.
4a. Number. The total number of term loans.
4b. Outstanding dollar amount. The total face amount
of term loans in thousands of dollars even if held at fair
value.
4c. Weighted average interest rate. Sum the outstanding
face amount of each term loan multiplied by its stated
nominal rate of interest – not the effective rate or
Annual Percentage Rate (APR). Divide the sum by the
outstanding dollar amount (column 4b.). Report the
rate in percent to three decimal places; for example, if
the average interest rate is 2¼ percent, enter “2.250.”
See appendix for example.
4d. Weighted average base rate. Sum the outstanding
face amount of each term loan priced with a base rate
multiplied by its base rate. Divide the sum by the total
outstanding face amount of loans priced with a base

rate. Report the rate in percent to three decimal places;
for example, if the average interest rate is 2¼ percent,
enter “2.250.” See appendix for example.
4e. Weighted average maturity. Sum the outstanding
face amount of each term loan multiplied by its
remaining maturity (in months). Divide the sum by the
outstanding dollar amount (column 4b.). Report the
weighted average maturity in months to two decimal
places; for example, if the average maturity is 18½
months, enter “18.50.” See appendix for example.
4f. Maximum maturity. Report the maximum maturity
in months.
4g. Number secured. The total number of term loans
secured by collateral of any kind.
4h. Dollar amount secured. The outstanding face
amount of term loans in thousands of dollars secured
by collateral of any kind.
4i. Number with U.S. Small Business Administration
(SBA) guarantees.1 The total number of term loans
with all or a portion of the loan guaranteed by
the SBA.
4j. Dollar amount with SBA guarantees. The outstanding face amount of term loans in thousands of dollars,
even if held at fair value, with all or a portion of the
loan guaranteed by the SBA.
4k. Number with other guarantees. The total number of
term loans with all or a portion of the loan guaranteed
by an entity other than the SBA.
4l. Dollar amount with other guarantees. The outstanding face amount of term loans in thousands of dollars,

1. For more information on SBA loan programs, see
https://www.sba.gov/loans-grants/see-what-sba-offers/sba-loanprograms.

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even if held at fair value, with all or a portion of the
loan guaranteed by an entity other than the SBA.

customer is not informed of the amount, are not to be
considered as commitments.

4m. Number with interest rate floor. The total number
of term loans that utilize interest rate floors in the loan
terms.

5a. Number. The total number of commitments.

4n. Number at interest rate floor. The total number of
term loans for which the nominal rate of interest equals
the interest rate floor.
4o. Dollar amount at interest rate floor. The outstanding face amount of term loans in thousands of dollars,
even if held at fair value, for which the nominal rate of
interest equals the interest rate floor.
4p. Weighted average interest rate floor. Sum the outstanding face amount of each term loan with an interest rate floor multiplied by its floor. Divide the sum by
the total outstanding face amount of loans with an
interest rate floor. Report the rate in percent to three
decimal places; for example, if the average interest rate
is 2¼ percent, enter “2.250.” See appendix for example.
Item 5 Outstanding C&I loans made under a
commitment (formal or informal) to U.S. small
businesses broken out by fixed rate and variable rate as
of the last calendar day of the most recent calendar
quarter.
Commitments are broadly defined to include all promises to lend that are expressly conveyed, orally or in
writing, to the borrower. Commitments generally fall
into two types of arrangements: formal commitments
and informal lines of credit.
A formal commitment is a commitment for which a
bank has charged a fee or other consideration or otherwise has a legally binding commitment. It is usually
evidenced by a binding contract, to lend a specified
amount, frequently at a predetermined spread over a
specific base rate. It requires that the borrower meet
covenants in the contract and pay a fee on the unused
credit available. These include revolving credits under
which the borrower may draw and repay loans for the
duration of the contract.
A line of credit is defined as an informal arrangement
under which the lender agrees to lend within a set
credit limit and to quote a rate on demand for a takedown amount and maturity requested by the borrower.
These arrangements may not be legally binding.
Authorizations or internal guidance lines, where the

5b. Commitment dollar amount. The total face amount
of unused and used commitments in thousands of
dollars.
5c. Outstanding dollar amount. The total face amount
of used commitments in thousands of dollars.
5d. Weighted average interest rate. Sum the face
amount of each used loan commitment multiplied by
its stated nominal rate of interest – not the effective
rate or APR. Divide the sum by the outstanding dollar
amount (column 5c.). Report the rate in percent to
three decimal places; for example, if the average interest rate is 2¼ percent, enter “2.250.” See appendix for
example.
5e. Weighted average base rate. Sum the outstanding
face amount of each used loan commitment priced
with a base rate multiplied by its base rate. Divide the
sum by the total outstanding face amount of used loan
commitments priced with a base rate. Report the rate
in percent to three decimal places; for example, if the
average interest rate is 2¼ percent, enter “2.250.” See
appendix for example.
5f. Number secured. The total number of commitments
secured by collateral of any kind.
5g. Dollar amount secured. The total face amount of
unused and used commitments in thousands of dollars
secured by collateral of any kind.
5h. Number with SBA guarantees. The total number of
commitments with all or a portion of the loan guaranteed by the SBA.
5i. Dollar amount with SBA guarantees. The total face
amount of unused and used commitments in thousands
of dollars, even if held at fair value, with either all or a
portion of the loan guaranteed by the SBA.
5j. Number with other guarantees. The total number of
commitments with all or a portion of the loan guaranteed by an entity other than the SBA.
5k. Dollar amount with other guarantees. The total face
amount of unused and used commitments in thousands
of dollars, even if held at fair value, with either all or a

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portion of the loan guaranteed by an entity other than
the SBA.

• Purchased factored loans (that is, purchased
accounts receivable).

5l. Number with interest rate floor. The total number of
commitments that utilize interest rate floors in the loan
terms.

7a. Number. The total number of term loans.

5m. Number at interest rate floor. The total number
ofcommitments for which the nominal rate of interest
equals the interest rate floor.
5n. Dollar amount at interest rate floor. The outstanding face amount of used commitments in thousands of
dollars for which the nominal rate of interest equals the
interest rate floor.
5o. Weighted average interest rate floor. Sum the outstanding face amount of each used loan commitment
with an interest rate floor multiplied by its floor.
Divide the sum by the total outstanding face amount
of used loan commitments with an interest rate floor.
Report the rate in percent to three decimal places; for
example, if the average interest rate is 2¼ percent, enter
“2.250.” See appendix for example.
6a. Net drawdowns on C&I commitments (formal or
informal) broken out by fixed rate and variable rate to
U.S. small businesses during the most recent calendar
quarter. Enter the net face amount of loans drawn in
thousands of dollars.
Item 7 New term C&I loans broken out by fixed rate
and variable rate to U.S. small business made during the
most recent calendar quarter.
Enter the amount of loans in thousands of dollars.
Include all term C&I loans to U.S. small businesses
entered into your books or loan system during the
most recent calendar quarter, even if the loans were
approved or disbursed in the prior calendar quarter.
Exclude loans approved or disbursed but not entered
into your institution’s books or loan system during the
most recent calendar quarter.
Also include:
• Renewals of term loans.
• Conversions of commitment into term loans.
Exclude:
• Loans purchased in the secondary loan market.

7b. Outstanding dollar amount.The total face amount
of term loans in thousands of dollars even if held at fair
value.
7c. Weighted average interest rate. Sum the outstanding
face amount of each term loan multiplied by its stated
nominal rate of interest – not the effective rate or APR.
Divide the sum by the outstanding dollar amount (column 7b.). Report the rate in percent to three decimal
places; for example, if the average interest rate is
2¼ percent, enter “2.250.” See appendix for example.
7d. Weighted average base rate. Sum the outstanding
face amount of each term loan priced with a base rate
multiplied by its base rate. Divide the sum by the total
outstanding face amount of loans priced with a base
rate. Report the rate in percent to three decimal places;
for example, if the average interest rate is 2¼ percent,
enter “2.250.” See appendix for example.
7e. Weighted average maturity. Sum the outstanding
face amount of each term loan multiplied by its
remaining maturity (in months). Divide the sum by the
outstanding dollar amount (column 7b.). Report the
weighted average maturity in months to two decimal
places; for example, if the average maturity is 18½
months, enter “18.50.” See appendix for example.
7f. Maximum maturity. Report the maximum maturity
in months.
7g. Number secured. The total number of term loans
secured by collateral of any kind.
7h. Dollar amount secured. The outstanding face
amount of term loans in thousands of dollars secured
by collateral of any kind.
7i. Number with SBA guarantees. The total number of
term loans with all or a portion of the loan guaranteed
by the SBA.
7j. Dollar amount with SBA guarantees. The outstanding face amount of term loans in thousands of dollars,
even if held at fair value, with all or a portion of the
loan guaranteed by the SBA.
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7k. Number with other guarantees. The total number of
term loans with all or a portion of the loan guaranteed
by an entity other than the SBA.
7l. Dollar amount with other guarantees. The outstanding face amount of term loans in thousands of dollars,
even if held at fair value, with all or a portion of the
loan guaranteed by an entity other than the SBA.
7m. Number with interest rate floor. The total number
of term loans that utilize interest rate floors in the loan
terms.
7n. Number at interest rate floor. The total number of
term loans for which the nominal rate of interest equals
the interest rate floor.
7o. Dollar amount at interest rate floor. The outstanding face amount of term loans in thousands of dollars,
even if held at fair value, for which the nominal rate of
interest equals the interest rate floor.
7p. Weighted average interest rate floor. Sum the outstanding face amount of each term loan with an interest rate floor multiplied by its floor. Divide the sum by
the total outstanding face amount of loans with an
interest rate floor. Report the rate in percent to three
decimal places; for example, if the average interest rate
is 2¼ percent, enter “2.250.” See appendix for example.
Item 8 New term C&I loans with SBA guarantees.
Check “yes” if your bank made new term C&I loans
with SBA guarantees to U.S. small businesses that were
sold during the most recent calendar quarter and that
your bank is still servicing. If “yes” is checked, complete question 9.
Check “no” if your bank did not sell new term C&I
loans with SBA guarantees to U.S. small businesses
during the most recent calendar quarter. If “no” is
checked, skip to question 10.
Item 9 New term C&I loans with SBA guarantees to
U.S. small businesses made and sold during the most
recent calendar quarter and the bank is still servicing.
Enter the amount of loans in thousands of dollars.
9a. Number. The total number of term loans sold.
9b. Sold dollar amount. The total dollar amount of
term loans sold in thousands of dollars.

9c. Weighted average interest rate. Sum the dollar
amount of each sold term loan multiplied by its stated
nominal rate of interest – not the effective rate or APR.
Divide the sum by the sold dollar amount (column
9b.). Report the rate in percent to three decimal places;
for example, if the average interest rate is 2¼ percent,
enter “2.250.” See appendix for example.
9d. Weighted average base rate. Sum the dollar amount
of each sold term loan priced with a base rate multiplied by its base rate. Divide the sum by the outstanding total amount of sold loans priced with a base rate.
Report the rate in percent to three decimal places; for
example, if the average interest rate is 2¼ percent, enter
“2.250.” See appendix for example.
9e. Weighted average maturity. Sum the dollar amount
of each sold term loan multiplied by its maturity (in
months). Divide the sum by the sold dollar amount
(column 9b.). Report the weighted average maturity in
months to two decimal places; for example, if the average maturity is 18½ months, enter “18.50.” See appendix for example.
9f. Maximum maturity. Report the maximum maturity
in months.
Item 10 New C&I loans made under a commitment
(formal or informal) broken out by fixed rate and
variable rate to U.S. small businesses during the most
recent calendar quarter.
Enter the amount of loans in thousands of dollars.
Include all C&I commitments to U.S. small businesses
entered into your books or loan system during the
most recent calendar quarter, even if the loans were
approved or disbursed in the prior calendar quarter.
Exclude loans approved or disbursed but not entered
into your institution’s books or loan system during the
most recent calendar quarter.
Also include:
• Renewals of or increases in commitments.
Exclude:
• Drawdowns on existing commitments (these should
be included in the response to question 6).
10a. Number. The total number of commitments.

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10b. Commitment dollar amount. The total face amount
of unused and used commitments in thousands of
dollars.

10m. Number at interest rate floor. The total number
ofcommitments for which the nominal rate of interest
equals the interest rate floor.

10c. Outstanding dollar amount. The total face amount
of used commitments in thousands of dollars.

10n. Dollar amount at interest rate floor. The outstanding face amount of used commitments in thousands of
dollars for which the nominal rate of interest equals the
interest rate floor.

10d. Weighted average interest rate. Sum the face
amount of each used loan commitment multiplied by
its stated nominal rate of interest – not the effective
rate or APR. Divide the sum by the outstanding dollar
amount (column 10c.). Report the rate in percent to
three decimal places; for example, if the average interest rate is 2¼ percent, enter “2.250.” See appendix for
example.
10e. Weighted average base rate. Sum the outstanding
face amount of each used loan commitment priced
with a base rate multiplied by its base rate. Divide the
sum by the total outstanding face amount of used loan
commitments priced with a base rate. Report the rate
in percent to three decimal places; for example, if the
average interest rate is 2¼ percent, enter “2.250.” See
appendix for example.
10f. Number secured. The total number of commitments secured by collateral of any kind.
10g. Dollar amount secured. The total face amount of
unused and used commitments in thousands of dollars
secured by collateral of any kind.
10h. Number with SBA guarantees. The total number of
commitments with all or a portion of the loan guaranteed by the SBA.
10i. Dollar amount with SBA guarantees. The total face
amount of unused and used commitments in thousands
of dollars, even if held at fair value, with either all or a
portion of the loan guaranteed by the SBA.
10j. Number with other guarantees. The total number of
commitments with all or a portion of the loan guaranteed by an entity other than the SBA.
10k. Dollar amount with other guarantees. The total
face amount of unused and used commitments in thousands of dollars, even if held at fair value, with either
all or a portion of the loan guaranteed by an entity
other than the SBA.
10l. Number with interest rate floor. The total number
of commitments that utilize interest rate floors in the
loan terms.

10o. Weighted average interest rate floor. Sum the outstanding face amount of each used loan commitment
with an interest rate floor multiplied by its floor.
Divide the sum by the total outstanding face amount
of used loan commitments with an interest rate floor.
Report the rate in percent to three decimal places; for
example, if the average interest rate is 2¼ percent, enter
“2.250.” See appendix for example.
Item 11 Select one answer to indicate how credit line
usage has changed during the most recent calendar
quarter.
No quantitative analysis is necessary in answering this
question.
Item 12 Select one answer per row to indicate the
importance of each reason for the change in credit line
usage during the most recent calendar quarter.
No quantitative analysis is necessary in answering this
question.
Item 13 Select one answer to indicate how loan demand
for U.S. small business C&I loans has changed during
the most recent calendar quarter.
Loan demand is defined as the amount of inquires via
loan applications or informal walk-in inquiries. No
quantitative analysis is necessary in answering this
question.
Item 14 Include all C&I loan applications received
from U.S. small businesses during the most recent
calendar quarter.
An application is defined as a formal document outlining the essential attributes regarding the financial position of the borrower on which the lender bases the
decision to lend. Exclude informal walk-in inquires
(these should be considered in the response to question 13). Applications approved include all loans that
your bank intends to make whether or not the loan
terms have been finalized, funds have been disbursed,
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or the loan has been entered into your institution’s
books or loan system.
14a. Number. The total number.
14b. Dollar amount. The total amount in thousands of
dollars.
Item 15 Check “yes” if your institution tracks lending
in low and moderate income (LMI) tracts for
Community Reinvestment Act (CRA) purposes or
voluntarily for other reasons.
If “yes” is checked, complete question 16.
Check “no” if your institution does not track lending
in low and moderate income (LMI) tracts for Community Reinvestment Act (CRA) purposes or voluntarily
for other reasons. If “no” is checked, skip to question 17.2
Item 16 Include all C&I loan applications received
from U.S. small businesses located in low and moderate
income (LMI) tracts during the most recent calendar
quarter.
16a. Number. The total number.
16b. Dollar amount. The total amount in thousands of
dollars.
Item 17 Select one answer per column to rank the most
common reasons for denying U.S. small businesses C&I
loans during the most recent calendar quarter.
No quantitative analysis is necessary in answering this
question.
Item 18 Select one answer to indicate how credit
standards for loans to U.S. small businesses have
changed during the most recent calendar quarter.
Credit standards are the internal policies and guidelines an institution uses to determine whether a borrower meets desired credit quality criteria. No quantitative analysis is necessary in answering this question.
2. For further information about CRA, see
https://www.ffiec.gov/cra/default.htm.

Item 19 Select one answer per row to indicate how C&I
loan terms have changed during the most recent
calendar quarter.
No quantitative analysis is necessary in answering this
question.
Item 20 Select one answer per row to indicate the
importance of each reason for tightening credit
standards or terms during the most recent calendar
quarter.
No quantitative analysis is necessary in answering this
question.
Item 21 If two or more reasons are classified as very
important in question 20, and one of the reasons is the
most important, identify that reason.
No quantitative analysis is necessary in answering this
question.
Item 22 Select one answer per row to indicate the
importance of each reason for easing credit standards
or terms during the most recent calendar quarter.
No quantitative analysis is necessary in answering this
question.
Item 23 If two or more reasons are classified as very
important in question 22, and one of the reasons is the
most important, identify that reason.
No quantitative analysis is necessary in answering this
question.
Item 24 Select one answer to indicate how the credit
quality of applicants has changed during the most
recent calendar quarter.
Credit quality is defined as the attributes a bank uses to
assess a borrower’s credit quality and probability of
default. The criteria includes, but is not limited to,
credit scores, quality of collateral, personal wealth,
debt to income ratio, and forecasted business growth.
No quantitative analysis is necessary in answering this
question.
Item 25 Select one answer per row to indicate how
credit quality has changed during the most recent
calendar quarter.
No quantitative analysis is necessary in answering this
question.

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Appendix: Weighted Average Calculation Examples
Outstanding dollar amount (thousands)

Interest rate

Base rate

Interest rate floor

Remaining maturity
(months)

500
420
290

4.25
4.1
4.3

2
n.a.
2.15

3.5
n.a.
3.75

18
4
10

Weighted average interest rate = [(500*4.25) + (420*4.10) + (290*4.30)]/(500 + 420 + 290) = 4.210
Weighted average base rate = [(500*2.00) + (290*2.15)]/(500 + 290) = 2.055
Weighted average interest rate floor = [(500*3.50) + (290*3.75)]/(500 + 290) = 3.592
Weighted average maturity = [(500*18) + (420*4) + (290*10)]/(500 + 420 + 290) = 11.22

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FAQS FOR INSTITUTIONS

Small Business Lending Survey

FR 2028D Reporting Questions and
Answers
General Questions
Question: Can the definition of a small business loan
for this survey be the same as that for Call Report section RC-C part II which states: “Report the number
and amount currently outstanding as of the report
date of business loans with “original amounts” of
$1,000,000 or less and farm loans with “original
amounts” of $500,000 or less.”?
Answer: One of the drivers of developing the
FR 2028D survey was that while all small business loans
will be relatively small, not all small loans are to small
businesses. So a key aspect of the FR 2028D survey is for
the size of the borrower to drive our pool of respondents.
The Survey Scope section of instructions states: “For the
purpose of this survey, U.S. nonfarm small businesses are
those nonfarm businesses domiciled in the U.S. with no
more than $5 million in total annual revenues.” If annual
revenues are not readily available on a bank’s data
system, please contact your FR 2028D analyst for additional information.
Question: What is the universe of loans that should be
included in loan amounts? Is it all C&I? All C&I made
to a small business?
Answer: It is all C&I loans made to a small business,
which is defined in the survey as a U.S. nonfarm small
businesses domiciled in the U.S. with no more than
$5 million in total annual revenues. The definition of
C&I loans, which can be found in the FR 2028D instructions—General Instructions, Survey Scope section, is the
same as that used for line Item 4 of Schedule RC-C
(FFIEC 031, 041, 051). For details, see the Call Report
instructions.

Question: Should CRE or agricultural loans to small
businesses be included in the survey?
Answer: No, only loans that are reported as C&I loans in
Schedule RC-C (FFIEC 031, 041, 051), line Item 4
should be included in the survey.
Question: Should matured and charged off accounts be
included in outstanding or new loans amounts?
Answer: No, matured and charged off loans should not
be included.
Question: When reporting the outstanding balance, is it
the contractual balance owed or the accounting book
balance, i.e., net of charge-offs, interest payments
received applied to principal, and deferred FASB fees?
Answer: Accounting book balance should be used.
Question: Where the survey asks for the number of
loans with other guarantors, this is defined as a guaranty by an entity other than the SBA. Does this refer to
other government entity guarantees?
Answer: Any loans with guarantees (other government
or otherwise) should be included.
Question: If an institution has both an SBA guarantee
and another type of guarantee, should the SBA guarantee take precedence, or should we include it in both
categories?
Answer: You should include those facilities in both categories.
Question: Do “other guarantees” include personal
guarantees?
Answer: Yes “other guarantees” include any guarantee
other than a SBA guarantee.
Question: For a commercial credit card portfolio, if it
includes the full range of liability structures (joint &
several, individual and corporate-only), should the
liability structure be treated as a personal guarantee?
Answer: No, liability structures should not be treated as
a personal guarantee.
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FAQs for Institutions

Question: Some of the institution’s commercial credit
card portfolios have recourse programs where their
partners—typically, national retailers—cover borrower
losses under certain conditions. Are such programs a
form of “other guarantees”?
Answer: Yes, such programs are a form of ‘other guarantees.’
Question: The category “Net Drawdowns on C&I
Commitments” could be a positive number if drawdowns exceed pay downs, but could also be a negative
number if pay downs exceed drawdowns. Is that correct?
Answer: Yes, “Net Drawdowns on C&I Commitments”
can be negative.
Question: For “Net Drawdowns on C&I Commitments”, should fees and interest be included when
making this calculation?
Answer: If it is capitalized into the loan, then Yes,
include it in the calculation for net drawdowns. If the fees
are outside the loan amount, then No.
Question: Should revolving lines of credit be reported
in this survey or just term loans?
Answer: Revolving lines should be included in commitments (line items 5, 6, and 10).
Question: Can an institution submit comments to
explain any assumptions, caveats, etc. regarding its
data submission?
Answer: No, there are currently no sections in the
FR 2028D survey to submit comments to explain any
assumptions or caveats. If an institution has any questions or comments, please contact or provide the information to your FRB analyst via email.

Line Item 4 Questions
Question: For outstanding dollar amount, the instructions ask for the total face value. Should the net or
gross balance of the loan be reported? If net, should
purchased participations be included?
Answer: The outstanding dollar amount should be
reported as it is reported in line Item 4 of Schedule RC-C, Part I (FFIEC 031, 041, 051). Purchased
participations should be included if the loan is a small
business loan as defined in the FR 2028D survey instructions.
Question: For line item 4b on the outstanding face
amount of term loans, does face amount mean the

original amount of the loans as detailed in the loan
contract? For example, if a loan that was originally for
$1,000,000 had paid down to $600,000, should
$1,000,000 still be reported for item 4b as that was the
face amount?
Answer:The face value of the loan when it was originated
was $1,000,000. But since line item 4 is asking for outstanding balance face amounts and $400,000 has been
paid down, then the outstanding face amount for this
question is $600,000.

Line Item 6 Questions
Question: Line item 6a (Net Drawdowns): What loan
types are you looking to be reported in this item? Is it
only revolving/credit or does it include term loans?
Would it just be new loans or does it include renewals?
Answer: Net drawdowns (drawdowns—repayments) of
outstanding commitments during the quarter. Note that
this is drawdowns less repayments in the current survey
period and not outstanding commitments in the current
survey period less outstanding commitments in the previous survey period.

Line Items 8 and 9 Questions
Question:Line items 8 & 9:If an institution only has
variable rate, term C&I loans with SBA guarantees
that were sold and it is still servicing the loans, should it
answer yes to question 8 and enter zeros for line item 9
since the variable rate column is grayed out?
Answer: In this case, the institution should answer no to
line item 8 and line item 9 will be grayed out. Graying out
the variable rate columns was an oversight when the
FR 2028D survey was designed. We plan to propose that
information on variable rate loans should be collected
when the survey is renewed, which if approved would be
for the June 30, 2020 as-of date. These loans should not
be incorporated into any other line item.

Line Items 14–16 Questions
Question:Line items 14 or 16 (Applications Received and
Approved): Should loan renewals be counted as an
application received/approved by the DI for this item?
Answer: Yes.
Question: Concerning the application information for
low and moderate income (LMI) tracts requested in
line items 16a and 16b, what should an institution

FAQ-2
August 2018

FR 2028D

FAQs for Institutions

report if it only tracks LMI for booked applications
and not applications received? Can the institution provide this information only for the booked loan data?
Answer: No, if the institution cannot provide both LMI
applications received and LMI applications approved,
line item 15 should be answered as “no” and line item 16
will be “grayed out” so that it will not be answered.

Question:Line items 15 & 16 (LMI applications):If an
institution does not track the LMI applications
received or approved, how should these items be
reported?
Answer: If an institution does not track LMI applications both received and approved, it should answer line
item 15 “no” and line item 16 automatically will be
greyed out.

FAQ-3
FR 2028D

August 2018