What is the best way to determine the purchase date on a CRA small business loan for purposes of reporting the action date?

We have a booking date that the purchased loan is added to our system. However, for our indirect lending group, the purchased loan is always effective on the contract/note date. This accounts for interest from the note date on the contract we purchased. So for the action date, are we to use the note date or the booking date?

Hopefully I am making this more complicated than it really is!

I would use the date the loan was purchased.

If the legal date the note is yours is different from booking, I would use the legal date you own the loan. A booking date date could be a week or so later.