Good afternoon!

We have a $2,000,000 Growth Capital Term Loan structured where $1MM is available at close and 2 additional $500,000 tranches available in increments upon borrower reaching respective milestones. Would the first $1MM tranche be reportable as CRA small business? Or should this loan be excluded from small business reporting because the total commitment is $2MM (subject to milestones), which is greater than the $1MM size limit? What if the borrower doesn't reach the required milestones? I'm not too familiar with Growth Capital loans so any thoughts would be greatly appreciated.

Thank you!

Are you a Large Bank? How are these notes being originated? One note? Multiple Notes? How will it map to your Call Report?