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#1516292 - 03/02/11 03:47 PM CRA Reporting - Loan Participations
BNKO Offline
100 Club
Joined: Sep 2009
Posts: 213
When reporting a participation for CRA purposes, do you report the entire participation amount, or just the amount the Bank is participating in?

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CRA
#1516305 - 03/02/11 03:59 PM Re: CRA Reporting - Loan Participations BNKO
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
From the FAQ:

§ll.42(b)(2)—4: When an
institution purchases a participation in
a community development loan, which
amount should the institution report—
the entire amount of the credit
originated by the lead lender or the
amount of the participation purchased?

A4. The institution reports only the
amount of the participation purchased
as a community development loan.
However, the institution uses the entire
amount of the credit originated by the
lead lender to determine whether the
original credit meets the definition of a
‘‘loan to a small business,’’ ‘‘loan to a
small farm,’’ or ‘‘community
development loan.’’ For example, if an
institution purchases a $400,000
participation in a business credit that
has a community development purpose,
and the entire amount of the credit
originated by the lead lender is over $1
million, the institution would report
$400,000 as a community development
loan.

§ll.42(a)(2)—1: When an
institution purchases a small business
or small farm loan, in whole or in part,
which amount should the institution
collect and report—the original amount
of the loan or the amount at purchase?

A1. When collecting and reporting
information on purchased small
business and small farm loans,
including loan participations, 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’s and TFR’s use of
the ‘‘original amount of the loan’’ to
determine whether a loan should be
reported as a ‘‘loan to a small business’’
or a ‘‘loan to a small farm’’ and in which
loan size category a loan should be
reported. When assessing the volume of
small business 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.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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