Interagency Q&A .22(a)(2) – 6: Do institutions receive consideration for purchasing loan participations?

Compliance > Regulation BB - CRA
Q:  § __.22(a)(2) – 6: Do institutions receive consideration for purchasing loan participations?
 
A:  Yes.  Examiners will consider the amount of loan participations purchased when evaluating an institution’s record of helping to meet the credit needs of its assessment area(s) through the origination or purchase of specified types of loans, regardless of examination type.  As with other loan purchases, examiners will evaluate whether loan participations purchased by an institution, which have been sold and purchased a number of times, artificially inflate CRA performance.  See, e.g., Q&A § __.21(a) – 1.
 
 
 
This Interagency Q&A, and others, was released in July 2016.  The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately.  They may be found here:  http://www.ffiec.gov/cra/qnadoc.htm
 

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