I 
117TH CONGRESS 
1ST SESSION H. R. 1977 
To amend the Internal Revenue Code of 1986 to exclude from gross income 
interest received on certain loans secured by agricultural real property. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 17, 2021 
Mr. KIND (for himself and Mr. FEENSTRA) introduced the following bill; 
which was referred to the Committee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to exclude 
from gross income interest received on certain loans se-
cured by agricultural real property. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Enhancing Credit Op-
portunities in Rural America Act of 2021’’ or as the 
‘‘ECORA Act of 2021’’. 
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SEC. 2. EXCLUSION FOR INTEREST ON LOANS SECURED BY 
AGRICULTURAL REAL PROPERTY. 
(a) IN GENERAL.—Part III of subchapter B of chap-
ter 1 of the Internal Revenue Code of 1986 is amended 
by inserting after section 139H the following new section: 
‘‘SEC. 139I. INTEREST ON LOANS SECURED BY AGRICUL-
TURAL REAL PROPERTY. 
‘‘(a) EXCLUSION.—Gross income shall not include in-
terest received by a qualified lender on any qualified real 
estate loan. 
‘‘(b) DEFINITIONS.—For purposes of this section— 
‘‘(1) QUALIFIED LENDER.—The term ‘qualified 
lender’ means— 
‘‘(A) any bank or savings association the 
deposits of which are insured under the Federal 
Deposit Insurance Act (12 U.S.C. 1811 et 
seq.), or 
‘‘(B) any entity wholly owned, directly or 
indirectly, by a company that is treated as a 
bank holding company for purposes of section 8 
of the International Banking Act of 1978 (12 
U.S.C. 3106) if such entity is a legal person— 
‘‘(i) organized, incorporated, or estab-
lished under the laws of the United States 
or any State of the United States, and 
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‘‘(ii) having its principal place of busi-
ness in the United States. 
‘‘(2) QUALIFIED
REAL
ESTATE
LOAN.—The 
term ‘qualified real estate loan’ means any loan se-
cured by agricultural real estate or by a leasehold 
mortgage (with a status as a lien) on agricultural 
real estate. For purposes of the preceding sentence, 
the determination of whether property securing such 
loan is agricultural real estate shall be made as of 
the time the interest income on such loan is accrued. 
‘‘(3) AGRICULTURAL REAL ESTATE.—The term 
‘agricultural real estate’ means— 
‘‘(A) real property which is substantially 
used for the production of one or more agricul-
tural products, and 
‘‘(B) any single family residence— 
‘‘(i) which is the principal residence 
(within the meaning of section 121) of its 
occupant, 
‘‘(ii) which is located in a rural area 
(as determined by the Secretary of Agri-
culture), which is not within a Metropoli-
tan Statistical Area (as defined by the Of-
fice of Management and Budget) and 
which has a population (determined on the 
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basis of the most recent decennial census 
for which data are available) of 2,500 or 
less, and 
‘‘(iii) which is purchased or improved 
with the proceeds of the qualified real es-
tate loan. 
‘‘(c) COORDINATION WITH SECTION 265.—Qualified 
real estate loans shall be treated as obligations described 
in section 265(a)(2) the interest on which is wholly exempt 
from the taxes imposed by this subtitle.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for such part III is amended by inserting after the item 
relating to section 139H the following new item: 
‘‘Sec. 139I. Interest on loans secured by agricultural real property.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
Æ 
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