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#467772 - 12/08/05 05:46 PM CRA
Rather be in Vegas Offline
100 Club
Joined: Oct 2005
Posts: 248
Florida
If we have a loan for $1,250,000 that would qualify under Community Development, but it will be split into a loan for $1MM and a line of credit for $250M. Due to the fact that the request is being split, would the loan amount of $1,000,000, make it a non reportable amount for community development?
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#467773 - 12/09/05 10:11 PM Re: CRA
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
Love your user name.

You will have two loans and the full amount of each can be used for Community Development purposes regardless of how the loan is structured as long as both loans qualify as a Community development activity.

If one loan does not meet the CD qualifying criteria then it is not counted.
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#467774 - 12/10/05 04:53 AM Re: CRA
Len S Offline
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Joined: Oct 2004
Posts: 2,090
Connecticut
Don is correct - as long as the two loans aren't reportable as small business loans in which case that would take precedent over the community development element for reporting purposes. So it is possible that breaking up the loans could disqualify them from being reported as Community Development loans. For example, if the borrower is a non-profit and you have secured the loans with commercial real estate then the loans would be reportable as small business loans and not as community development. But if the loans were unsecured, then they wouldn't be reportable as small business loans and could be reported as community development. If the loans are disqualified as CD, you can still get credit during an exam if you document those loans and convince examiners that they qualify as defined by community development.
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