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#2294019 - 02/22/24 08:26 PM Purchase of pool of SBA 7a loans for CRA credit
Red Raiders Offline
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Red Raiders
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Compliance Land
We are looking at ways to enhance our community development investments. One idea that came up was to purchase the guaranteed portions of SBA 7a loans. Has anyone done this and what information would we need about the underlying loans in order for them to qualify?
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#2294093 - 02/24/24 12:52 AM Re: Purchase of pool of SBA 7a loans for CRA credit Red Raiders
Len S Offline
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Joined: Oct 2004
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Connecticut
The SBA loans don't qualify for CD credit simply because they are SBA loans. They must be for a qualified CD purpose, typically "economic development" which is interpreted to mean job creation, preservation or improvement primarily for LMI persons. They could potentially qualify under revitalization/stabilization if you can demonstrate the loan is consistent with a government plan for a targeted tract. Like any CD loan or investment you need the documentation to substantiate the CD purpose is being fulfilled.
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#2296951 - 05/08/24 04:03 PM Re: Purchase of pool of SBA 7a loans for CRA credit Red Raiders
Red Raiders Offline
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Red Raiders
Joined: May 2013
Posts: 1,082
Compliance Land
Thanks, Len.

I'm told we don't have a good way to get the underlying information about the specific loans in an SBA pool. Would it make a difference if the pool only consisted of loans $1mm or less?

Curious to see if anyone has any experience getting the info needed to qualify an SBA loan pool for CRA credit.
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