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?