What is required when reporting purchased loans?

Do we report the original loan amount or the purchased loan amount?

Do we have to report gross annual revenue? and have supporting documentation in file?

Page 49 of the CRA Guide:
(2) For loan participations and
syndications, the “original
amount” of the loan participation
or syndication is the entire
amount of the credit originated by
the lead lender.

This is not a participation loan.
We are purchasing @ 100 loans.

Can we report the loans if the bank we are purchasing them from is also reporting the loans (them as an origination - us as a purchase)?

Do we have to report gross annual revenue? and have supporting documentation in file?

Sorry! My bad!
Check out pages 45 and 47 and see if that answers your questions.

Small-Business
and Small-Farm Loans
The CRA regulations require a large
institution to collect and maintain, in
electronic format, until the
completion of its next CRA
examination, the following data for
each small-business or small-farm
loan originated or purchased by the
institution:

a unique number or alphanumeric
symbol that can be used to identify
the relevant loan file;

the loan amount at origination;

the loan location; and

an indicator of whether the loan
was to a business or farm with
gross annual revenues of $1
million or less

Yes on the gross revenues and what kind of documentation are you talking about?

Page 11
Original Amount
vs. Purchase Amount
When collecting and reporting
information on purchased smallbusiness
and small-farm loans, an
institution collects and reports the
amount of the loan at origination,
not at the time of purchase. This is
consistent with the Call Report and
TFR guidelines, which use the
“original amount of the loan” to
determine (1) whether a loan should
be reported as a “loan to a small
business” or a “loan to a small farm”
and (2) in which loan-size category a
loan should be reported. When
assessing the volume of smallbusiness
and small-farm loan
purchases for purposes of evaluating
lending-test performance under
CRA, however, examiners will
evaluate an institution’s activity
based on the amounts at purchase.

Thanks for all your help - We haven't purchased the loans yet so I am not sure of the quality of the files/documentation.

Can we report the loans if the bank we are purchasing them from is also reporting the loans (them as an origination - us as a purchase)? This is not an affiliate so I am guessing yes - I have read through page 11 but get really confused w/ affliate, consortia, etc.

Thanks again,

I'm guessing yes since at some point all loans have to be originated and it says originated or purchased.

Your bank might be doing reviews of the loans as part of their due diligence so that may be enough documentation.

I am currently reviewing purchased loans for business purposes. Some of the files have no income information other that what is listed on the Loan Summary Page. It is listed there, so income was used in the decision. Can I use this number without having tax returns or financial statements to back it up?

Do we have to report the action date for purchased loans? If so, do we report the date we purchased the loan or the original date of the loan?

6. Action taken date—loan purchased. For covered loans purchased, a financial institution reports the date of purchase.