OK, so I'm new the CRA Reporting side of things (I have primarily been working on CD activity collection up to this point).
Last edited by wblewis935; 11/01/17 08:43 PM.
It's my understanding that Institutions are to report on the original or renewed amount of a loan, not the net balance after selling whatever portion to the secondary market.
Consider the following example:
If the bank originates a $1.5MM commercial loan that is NOT CD, and sells $500,000 to the secondary market, leaving a net book balance of $1MM, the bank would still not report this as a small business loan because the amount of the loan at origination was over $1MM.
So, in this case, no CRA Small Business loan would be reported at 1.5MM.
Do I understand that correctly? I don't want to report the retained amount of a loan without CD purpose that was sold to the secondary market.
Any help/guidance/reference would be helpful! I found some information from the Q&A regarding the [/i]purchasing[i] of participations, but was unable to find explicit guidance on selling participations.