I have a question for the gurus regarding syndicated loans and CRA reporting. Example: If we are the agent bank for a $800,000 syndicated loan transaction (non-community development) where we will hold $500,000 and a participating lender will have a $300,000 portion, what loan amount should be reported for CRA small business? Would both the agent bank and participating lender report the total amount of $800,000? I've seen some threads regarding loan participations, but I am a little confused. Is there a difference between a loan participation and a syndicated loan for CRA reporting purposes?
Also, my understanding is that if this loan qualified as a community development loan (not small business), the agent bank would only report the amount held of $500,000. Is this correct?
Any thoughts would be greatly appreciated! Thank you!!