Our bank recently bought the participation interest from the lead bank so that we are now a 100% owner of the loan. There was an assignment of mortgage to reflect our 100% ownership interest in this loan. Is this loan a reportable loan since we only purchased the lead bank's participation piece of the loan?

You previously purchased a partial interest; that was not reportable. You have now purchased a second partial interest, now owning 100%, but still a purchase of a partial interest.

I am inclined to not report since it it simply two partial interest purchases at different times.

Commentary:

8. 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.