We are planning to make two separate loans in connection with a multi-party loan facility that will be used to bridge investors in a low-income housing tax credit fund. We likely will structure our participation in the form of a 3-yr revolver followed by a longer-term term loan, in order to provide us with greater protection in the event that problems arise during the draw-down period. At no point will $ greater than 1 loan be outstanding. Although both commitments will be made up front (the second one containing appropriate covenants, etc), we view and will book them as separate facilities. Am I correct in expecting that we will receive CRA credit for 2 loans, similarly to a bank that does the construction and the takeout for a real estate project? Is there anything more I need to do to demonstrate that they are 2 separate loans? Do I need to specifically document 2 separate credit decisions?

If you have two notes you have two loans. you should document them separatly.

I have now learned that the two loans will be embedded in a single loan facility, so there may not be 2 notes. Under that scenario, is there a viable argument for taking credit for two separate loans? Again, I see a parallel (in substance) to the case of a construction loan and permanent takeout; though it looks different, adminstratively, because in that case there would be 2 separate notes.

I don't understand, you will have one note? that has a duel purpose. Like having a line of credit and there is a letter of credit carved out of the line??? Or you have one committment and under that committment you have the two notes?