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#2171284 - 04/02/18 02:36 PM participation loan reporting
Learning Compliance position Offline
New Poster
Joined: Aug 2012
Posts: 19
Hey everyone I need some help, i have referanced the CRA guide to data collection, however i just need a clear cut answer on this:

Scenario 1: My bank is buying into a participation loan. The original amount is 2 million but my bank will have about $500,000. participation loan. The loan is coded as commercial.
We are a Large bank institution. So do I report this on my SBSF data submission and if so what would my loan amount be the $500,000?

Scenario 2: My bank is buying into a participation loan. The original amount is 750,000 but my bank will have about $350,000. participation loan. The loan is coded as commercial.
We are a Large bank institution. So do I report this on my SBSF data submission and if so what would my loan amount be the $350,000?

Thanks

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#2171293 - 04/02/18 03:12 PM Re: participation loan reporting Learning Compliance position
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 778
We have always gone by the following, however I would love to hear other comments.

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.’’

Scenario 1 : Since the original amount of the credit is >$1,000,000 you would not report your participation portion on your SBSF submission.

Scenario 2: Since the original amount of the credit is <= $1,000,000 you would report your participation portion of $350,000 on your SBSF submission.

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