Hi All. We do a few SBA loans. At closing, we have 2 loans on our books: our permanent loan, and the temporary loan that will eventually be taken out by the SBA financing. Thoughts on whether I include the SBA temporary financing in the origination count to determine if we're reportable? Or whether they are reportable as a small business loan once we do start reporting?

I see no exclusions from the definition of a covered credit transaction based on a temporary nature, unless I missed it somewhere.

I'm not seeing it either.

rlcarey and InFairness, thank you. I didn't see anything either, but I'm always for better safe than sorry later.

Many commercial loans are "temporary" in nature, such as 90-day notes for seasonal financing. They would be reportable under 1071 if they are extended to a small business and not an excluded transaction.

There is also the pessimist who would say nothing like this is temporary until it has been purchased, transferred and off the books. Stuff happens.