I *think* I know the answer to this, but I wanted some confirmation from the experts.

We have a loan from a few years ago (we were not a CRA reporter then, I don't think that's relevant though) that was a regular closed end credit term loan. The loan has been paid down some and now the lender has done a modification agreement to increase the loan balance back to the original loan amount by making an advance on the loan and disbursing to the borrower.

The loan hasn't matured, so it's not really a "renewal". It's not a line of credit that's being increased. The loan itself would be a small business loan if it were a new loan.

I think that because we're advancing new funds, we should report it. I also think we should only report the amount of the new funds advanced, and not the total loan, but I'm not sure about that.

Hopefully I haven't left any important details out... should we report this? And if so, what amount?

Thanks in advance for any suggestions!

I think you will find your answer in the Q&A section of the Reg. BB )Section .42 Q5.

So you didn't change the term? (just re "upped" the money to the original amount)?

You also didn't change the loan number? (Meaning you didn't refi it?)

I'd go with the increase amount reported as a new loan this year. BUT !!! If this would cause a data integrity nightmare due to system issues, I'd report the entire amount of the debt (new money and old balance) on the LR. I'd just be consistent in that reporting. (I'd then go hit the lender in the head and tell them to make life easier for ALL and rewrite the note as a new note next time).