Doing a $4million deal: $2.5 is to refinance from another bank, $1.5 is to expand the business and add new jobs.
Part of the loan qualifies for a "Jobs for New England" program which provides for an interest rate reduction/subsidizes from the FHLB when the loan creates or retains jobs.
The situation is I have to book that part as a loan of $1 million, with it's own loan number; the remaining $3 mill as a different loan.

From one point of view that $1mil is now a small business loan; BUT if I look at the $1.5 million as one "investment" then I can claim it as a CD loan. (not claiming the other $2.5 as it was just a straight refi of debt.)

Or can I only claim $500,000 ( of the $3 mil loan) as CD?

Thoughts?

It's too bad the 1MM loan isn't a dollar above 1MM or else this would be easy! But, I would utilize the qualitative information from the first loan, and use that to validate the 3MM if it has a primary purpose. You've thrown a lot of numbers around, but I'm working off of the premise that you are putting 1MM in one note, and 3MM in another note.