$19,000 participation bought in a low income housing apartment complex under a CRA Investment program (loan pool obligation).

Do I actually have a CD loan write-up to do? I'm not quite sure how to tackle this one because the amount is so small. TIA!

It sounds to me like you have a CD loan but you combine the terms "investment program" and "loan pool" which makes it a little confusing. Are you accounting for this as a loan or an invesment? In any case, any community development activity (loan or investment) should have plenty of documentation to support the community development nature of the activity. So you should have a file of details maintained.

We are hoping to count our membership in the loan pool as an investment, and then count the individual loans as CD as well. Please let me know if I need to handle this in a different manner. I'm flying blind.

If you have to pay something separate to participate in the loan pool, then it sounds like you have the correct path. However, if you simply contribute to the pool for which individual loans are made, then you would classify them as EITHER an investment or loans, depending how you carry them on your books.

Thanks Bonnie. We had to pay an "enrollment fee" and pledge to lend up to a certain amount when we joined the loan pool. We are carrying each individual loan on our books just like any other participation bought, so I guess I'll stick to my plan. Thanks for verifying it!

Oh, great response on my other thread, BTW.