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#1788471 - 02/22/13 05:11 PM Loan Participations
notuntermywatch Offline
Gold Star
Joined: Jun 2006
Posts: 392
MN
We originate several commercial purpose loans that are subject to HMDA (rehab/rental; rehab/resell). These are typically large organizations we borrow to and sometimes we will run into a legal lending limit issues so we have to participate or sell the loan to one of our affiliate banks.

In reading the GIR, if the lead bank keeps over 50% of the loan, we would not report a purchaser code. However, if we sold more than 50% to one of our affiliates, I would have to report that purchaser code on my LAR correct?

And if I report it on my lead bank LAR, even if we sell 100%, we only report it on the lead bank, not on the purchasers LAR, RIGHT?

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#1788490 - 02/22/13 05:49 PM Re: Loan Participations notuntermywatch
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,844
Bloomington, IN
Where in the GIR are you getting the 50% from for reporting participation loans?

If you are the lead bank you report the loan. Those banks purchasing a part of the loan do not report at all.

Participation loan. An institution that
originates a loan and then sells partial
interests to other institutions reports
the loan as an origination. An institution
that acquires only a partial interest
in such a loan does not report the
transaction even if it has participated
in the underwriting and origination of
the loan.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1788576 - 02/22/13 08:07 PM Re: Loan Participations Dan Persfull
notuntermywatch Offline
Gold Star
Joined: Jun 2006
Posts: 392
MN
My bad, 50% isn't in the GIR, just reading into the partial.

My question relates to the purchaser code. If I keep 90% of the part and sell 10%, then I would still report the loan, but may not include the purchaser code.

If I keep 30%, and sell 60% then I would report the purchaser code.

Thanks

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#1788598 - 02/22/13 08:49 PM Re: Loan Participations notuntermywatch
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,844
Bloomington, IN
You are not selling the loan. You are selling an "investment" opportunity in the loan for other banks to participate in. Since you are not selling the loan there would be no purchaser code to report.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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