Our bank purchased $250,000 of a $1MM participation loan originated by another institution (non-affiliate). The loan is collateralized by accounts receivable. Just want to verify that we should report the $250,000 on our CRA loan register? Thank you.

That should be correct, 228.33(d)(2)(ii).

I need to throw this back up to the front. First of all, I think the site should be 228.22, not 228.33. (I can't find a 33).

My question - I don't view "purchased" loans the same as I do "participations". I realize that purchased loans are reportable on the CRA LR, provided they meet the reporting criteria. These would be loans that we have just purchased, without being involved in the original transaction.

I understand a "participation" to be a loan where we join with other banks and take a portion of a larger credit. "Participations" are only subject to CRA reporting if they meet the definition of community development.

Is my understanding correct?

Oops. "Cite", not "site". Brain is appropriately mush as the filing deadline looms.

If you originate the participation loan you would report it if it meets all other reporting criteria. If you are just a player, you report for CD purposes only.