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#2276357 - 10/04/22 08:48 PM CRA LR Reportability - Purchased SBA loans
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 147
San Antonio, TX
While I know we can report participations purchased depending on the overall commitment amount, can we report loans we've purchased outright from a capital group (SBA) on our CRA LR? That would mean someone else originated them. Thanks for looking into this and getting back to me.

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#2276364 - 10/04/22 09:50 PM Re: CRA LR Reportability - Purchased SBA loans Help! Compliance
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,090
Connecticut
Purchased loans are counted the same as originated loans for CRA evaluation purposes. Just be sure that you are purchasing a loan and not purchasing an investment. As always, refer to the Call Report codes for identifying small business loans.
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#2276439 - 10/06/22 01:22 PM Re: CRA LR Reportability - Purchased SBA loans Help! Compliance
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 147
San Antonio, TX
While purchased loans are counted the same for CRA evaluation purposes, are they to be added to the CRA LR that is submitted annually?

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#2276529 - 10/10/22 07:11 PM Re: CRA LR Reportability - Purchased SBA loans Help! Compliance
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,090
Connecticut
Yes - there is an action code, "6" that denotes a loan that was purchased.
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#2276561 - 10/11/22 09:58 PM Re: CRA LR Reportability - Purchased SBA loans Help! Compliance
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 147
San Antonio, TX
Oh...Are participations purchased to be reported as originations...or also purchases?
Last edited by Help! Compliance; 10/11/22 10:26 PM.
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#2276566 - 10/12/22 01:26 AM Re: CRA LR Reportability - Purchased SBA loans Help! Compliance
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,090
Connecticut
The Q&A's consistently refer to "participations purchased" but there is no specific mention of the action code. I would use the purchased code for the activity type. But it really doesn't make a difference since loans originated and loans purchased are treated the same for CRA evaluations.
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CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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#2279156 - 12/22/22 10:12 PM Re: CRA LR Reportability - Purchased SBA loans Help! Compliance
comply1 Offline
New Poster
Joined: May 2019
Posts: 5
This thread made me question loans that are serviced by an institution. Could a loan that was not originated by an institution, but is serviced by them be reported on their Small Bus/Small Farm LR?

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#2279157 - 12/22/22 10:16 PM Re: CRA LR Reportability - Purchased SBA loans Help! Compliance
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Why in the world would report a loan if all you had were servicing rights? If you were servicing loans for a qualified non-profit for free, you might get some credit, but you would not report them.
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