I have 2 questions.

1. For partipations purchased, is my action code 1 or 6? (These are individual loans the bank purchased, not a portfolio of purchased loans.)
2. For participations sold, does the originating bank still report the original amount of the loan?

Example
Bank A - originates a $200,000 small business loan & sells $150,000 to Bank B. Does Bank A report $200,000?

Bank B - reports $200,000 as a small business loan


Thanks.

First, CRA includes loan originations and loan purchases so the course of action is somewhat moot. However, I would recommend that you treat a participation that you purchased as action "6". Don't forget that you are supposed to report the entire amount of the loan, not just the portion you purchased or participated in and the rules for reporting are based on the entire loan amount. Also, you are supposed to report the value of the loan at origination. In your examples the correct amounts to report would be the $200,000 for both banks although examiners are supposed to evaluate your performance only on the amount you purchased. See _.42(a)(2).

A caveat for CD loans- the rules for community development loans were changed effective January 2009. In the case of CD loans you do report the amount purchased, not the value of the total loan.

Thanks for the clarification.