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#1483113 - 12/20/10 10:23 PM Community Development Loan Commitment
Busy body Offline
100 Club
Joined: Nov 2004
Posts: 160
Texas
We are structuring a community development “investment” in a small business investment fund as a community development loan. We just made a loan commitment in December 2010, but we will not fund until beginning in 2011 when individual loans in our assessment area are identified . Do we report this as a community development loan for the total amount of the commitment for 2010 or must we report only the amounts as they fund in 2011 and beyond? Thanks in advance for any feedback!

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CRA
#1483135 - 12/20/10 11:17 PM Re: Community Development Loan Commitment Busy body
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,143
Connecticut
Your language is confusing because you intermingle "investment" with "loan". You are supposed to report loans and investments when they are closed or funded. However, during a CRA PE you can get credit for a commitment that was not funded during the PE period if it is a legally binding commitment.
Your wording suggests that you may be participating in a line of credit facility extended to a local entity such as a housing development fund. If you made a formal commitment for a line of credit facility the commitment can be reported as a CD loan in its entirety when you make the commitment and whenever you renew it subject to the once per year rule.
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