Hi- I was wondering if SBA Loans specifically SBA Express Loans (7A), can be considered Community Development Loans. We are in need of Community Development Loans, and make a lot of SBA Express Loans, and wanted to see if we can get any Community Development Credit for these Loans.

Thanks!

SBA loans would be counted under the bank's innovative and flexible lending programs.

If the loan was a SBA 504 it could count for CD Loan Credit. This government program has economic development (job creation)that qualifies it as a CD Loan.

Thank you!

I forgot to mention the SBA 504 would need to be over $1 million dollars to count as a Community Development Loan.

Just to clarify, as stated above, if the loan is $1 million or less it is a CRA Small Business loan. If greater than $1 million it will be eligible for community development credit. Loans that meet the definition of small business or small farm must be placed in that category (but refer to the Q&A for special rules for ISBs.)

For 504 deals, we provide a term loan to cover 50% of the deal as well as a time note (short term bridge loan) for the 40% that will be taken out once the SBA debenture funds (they fund simulataneously at closing). In order to receive CD credit for these deals, does our 50% loan need to be greater than $1MM or is it a combination of the 50% term loan and 40% time note? Since there is risk that the debenture doesn't fund, we initially have a 90% exposure on these deals.

For example, we have a deal for total exposure of $1.5MM as follows. Could we receive CD credit since our initial combined exposure is $1.35MM or do we have 2 small business loans?

- Bank term note (50%) = $750,000
- Bank time note (40%) = $600,000
- Borrower contribution (10%) = $150,000

I appreciate the input.