We are currently reviewing our CRA Portfolio of Investments and heard that banks need to report Public Welfare Investments (PWI) by filing forms (OCC - CD1 or Federal Reserve H-6) within 30 days following an investment. We understand that it may be appropriate for filing notices when investing in EQ2 or CDFIs - but wanted to get thoughts it is it necessary on ALL investments - to include LIHTC (Funds and Direct), HUD Bonds and general CRA funds?

Thanks and appreciate some clarification!

Looking for information for banks capturing credit on syndication loans (ex: who gets credit, is it only the lead bank or majority loan proceed bank?) Appreciate any information that can be shared or you can direct me to.... Thanks!

Loans extended by consortia are eligible for credit only as community development loans, not as small business loans. The rules for splitting credit for CD loans generated by consortia can be found in subsection .22 of the Regulation. Also pages 10-11 of the CRA Guide address this issue.