We have a CRA reportable loan with a loan amount less than 1 mil that renewed in 2005. Subsequent to the renewal, but still in 2005, an additional advance was granted taking the loan amount over 1 Mil, thus making the loan not reportable. We are reporting the renewal of less than 1 mil only rather than not reporting the loan at all. I did not find this scenerio in the CRA LR guide - am I right in this stance?

It sounds like you are correct. The renewal of a loan of $1 million or less would be reportable. Now, when the amount was increased to more than a million subsequent to the renewal, how was the additional money documented? Was it in the form a a totally new note incorporating all the previously advanced funds, or was it in the form of an additional note for the additional money only? If the latter, was the advance considered part of a line of credit, or do the individual loans stand on their own? If you had a renewed loan for, let's say $800K and then two months later, your bank advanced an additional $500 how you handled the transactions would determine if they are reportable. If you kept the $800K note untouched and simply advanced another $500K on another note (not under a line of credit) both the $800K and the $500K would be reportable even though combined they exceed $1 million. So it is possible that you should report the advance that brings total loans in excess of $1 million as long as the notes were distinct and not part of a line of credit

They were in the form of an additional advance to the original note - the original note was modified, extending the total to exceed the 1MM mark as opposed to 2 separate documented notes (2 loans) as you suggest in your response. Thanks for the affirmation!