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#1965324 - 09/29/14 03:11 PM SBA 504 - Large Bank
CRA Ray Offline
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Joined: Sep 2014
Posts: 3
Alabama - Florida
I've read mix messages regarding SBA 504 loans. I'm regulated by the FRB as a Large Bank, can an SBA 504 be considered as a Community Development Loan if the loan amount is $1 million or above? As long as the loan meets a community development purpose.

Thank you in advance.

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CRA
#1965329 - 09/29/14 03:22 PM Re: SBA 504 - Large Bank CRA Ray
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
As long as it meets a CD purpose, yes, which for 504 is often jobs. The only confusion is because if the loan is $1 MM or less it will usually be small business.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1965779 - 09/30/14 07:12 PM Re: SBA 504 - Large Bank Kathleen O. Blanchard
Jordan Blanchard Offline
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Joined: Jun 2014
Posts: 1
A 504 first over $1MM does not have to have a CD purpose. See Federal Register / Vol. 79, No. 175 / Wednesday, September 10, 2014 / Notices which notes what is an example of CD loan.

businesses, in an amount greater
than $1 million, when made as part of
the Small Business Administration’s
504 Certified Development Company
program;

504 firsts are considered to be CD loans because of the job creation/retention requirements for the program.

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#1965887 - 09/30/14 09:45 PM Re: SBA 504 - Large Bank CRA Ray
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
That is because they have a jobs component built in.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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