Participations Sold

Posted By: wblewis935

Participations Sold - 11/01/17 07:26 PM

OK, so I'm new the CRA Reporting side of things (I have primarily been working on CD activity collection up to this point).

It's my understanding that Institutions are to report on the original or renewed amount of a loan, not the net balance after selling whatever portion to the secondary market.

Consider the following example:
If the bank originates a $1.5MM commercial loan that is NOT CD, and sells $500,000 to the secondary market, leaving a net book balance of $1MM, the bank would still not report this as a small business loan because the amount of the loan at origination was over $1MM.

So, in this case, no CRA Small Business loan would be reported at 1.5MM.

Do I understand that correctly? I don't want to report the retained amount of a loan without CD purpose that was sold to the secondary market.

Any help/guidance/reference would be helpful! I found some information from the Q&A regarding the [/i]purchasing[i] of participations, but was unable to find explicit guidance on selling participations.

Thanks everyone!
Posted By: Len S

Re: Participations Sold - 11/16/17 10:30 PM

You are correct. The original amount of the loan would be the basis for the determination. In this case, the $1.5MM would disqualify the loan as small business
Posted By: wblewis935

Re: Participations Sold - 01/16/18 08:09 PM

Ok, so I need to revive this with an additional question.

If the loan IS reportable, meaning the original amount of the loan is $1MM or less, do I report the original amount, or only the amount the bank retained after a portion was sold?

Thank you!