Syndicated Loans

Posted By: HMDA CRA Gal

Syndicated Loans - 04/15/20 06:44 PM

Good Afternoon,

I have a question for the gurus regarding syndicated loans and CRA reporting. Example: If we are the agent bank for a $800,000 syndicated loan transaction (non-community development) where we will hold $500,000 and a participating lender will have a $300,000 portion, what loan amount should be reported for CRA small business? Would both the agent bank and participating lender report the total amount of $800,000? I've seen some threads regarding loan participations, but I am a little confused. Is there a difference between a loan participation and a syndicated loan for CRA reporting purposes?

Also, my understanding is that if this loan qualified as a community development loan (not small business), the agent bank would only report the amount held of $500,000. Is this correct?

Any thoughts would be greatly appreciated! Thank you!!
Posted By: HMDA CRA Gal

Re: Syndicated Loans - 04/16/20 03:00 PM

Posted By: HMDA CRA Gal

Re: Syndicated Loans - 04/20/20 08:09 PM

I would like to add too that in this example, there would separate notes for each lender. There would be a note payable to our bank (the lead) in the amount of $500,000 and a note payable to the participating lender in the amount of $300,000 for the total loan amount of $800,000. Does the fact that separate notes are done for each participant play a factor in how these loans should be reported for CRA purposes? Please, any thoughts on this is greatly appreciated. Thank you!