We did a business purpose loan to an individual in February of 2007 for $200,000. We reported this loan on our CRA/LAR as an origination for $200,000. Last month, this loan was refinanced for $500,000.

Normally I would report the additional $300,000 (since the $200,000 has already been reported in February) and be on my way.

The fly in the ointment here is the new loan was not written in the individuals name (John Smith) but rather in his business name (ABC Company).

My question is do I treat this as an entirely new loan and new money by reporting all $500,000 since the borrower is not the same? Or do I still only report the the $300,000 since $200,000 of the money has already been reported. It seems like I should report all $500,000 since there is technically a new borrower involved (even though they are related interests), but it also seems that by doing so I would be double counting the $200,000 that was originally reported in February.

Any thoughts?

Travel Girl is it the same loan? Or did the bank do another loan replace the loan in February with the new 500,000 loan to the business?

Bubs - A new note was signed and given a new number. The original note for $200,000 was a single pay unsecured loan for 30 days for business expenses. I was mistaken earlier. The first loan was done in May not February. It came due in June.

In its place a new note was prepared - now in the business name - as a revolving line of credit for $500,000, interest is due monthly, principal is at maturity.

It looks to me that I have all of the elements of a refinance to a new borrower so I'm thinking I should count the full $500,000 - but I can't get past the double counting of the first $200,000 because in reality the money went to the same person and I've already counted $200,000 in May.

You should count the 500,000 as a seperate loan. I know feels weird but thats the reg. You have two seperate borrowers so two seperate loans.

Bubs - that's my thought too. Thanks for getting back to me. Have a great weekend.

I hope ours is better than the last couple of days. I'm in Mpls - the site of the horrific bridge collapse.

I would also report the two separate loans.

Geez, travelgirl, the whole city must be in shock. I want you to know that there are people all the way over here in California that are thinking about about eveyone involved with this terrible accident and how it would affect the whole city, our hearts go out to you.

I would say 2 loans.