Advantages and Disadvantages of Participated Loans

By September 13, 2022Blog

Participated loans require ongoing monitoring, and they are not a “set it and forget it” investment. It takes time and close communication with the lead bank to ensure a smooth operation. Investing in such a loan requires a calculated level of risk, which can include high interest rates and low loan volume. However, investing in loan participations can be a great addition to your overall strategy to manage your bank’s balance sheet.

Issues with loan participations

When considering the advantages and disadvantages of loan participations, it’s important to be realistic. While loan participations can be a great way for lenders to mitigate risk and provide capital to borrowers, there are other risks to consider. These risks can be mitigated by working with a partner that has good economic health and a great track record.

While many community banks still view loan participations as an effective way to diversify risks, leverage the expertise of another lender, and gain access to a particular market segment, the type of loan you chose is important.  As a result, many community banks are limiting their exposures to loan participations and vow to only participate in high-quality deals with well established originators.

In the past, loan participation agreements allowed the lead bank to retain certain fees. These fees could include non-usage fees on revolving lines of credit, late fees, and pre-payment penalties. These fees are not always required to be shared pro-rata. The lead bank can retain them if the loan fails.

When evaluating a loan for consideration, be sure to check the underwriting standards, the policy limits, and monitor the guidelines set forth by your partner bank. Always know you can propose amendments to the agreement, if the originator is open to it.

In the past decade, loan participation activity has fluctuated, with a peak in the early 2000s and a decline during the 2008-09 financial crisis. However, activity has recovered over the past few years. In fact, the FDIC has recently issued guidance for banks on how to use loan participations effectively to ensure their risk management programs are effective.The rise in loan participations as a balance sheet management tool has led to the development of loan participation automation tools like Participate.

Limitations on loan participations

Loan participations are an excellent way for small and midsized banks to team up and diversify their portfolios. They allow the originating institution to maintain the lead relationship with the borrower while staying below their lending limit. 

As with any investment, there are risks involved. Loan participations require close monitoring and review. The bank must be in constant communication with the lead bank and follow up on compliance and risk assessments. It is important to understand the risks associated with loan participations so that it can establish investment goals. These may include calculated risk investment strategies, expanding the service area, or increasing the loan volume.

Another important factor is determining if a participation arrangement is appropriate for the specific situation. Some institutions are not comfortable with the idea of becoming a lender of record, and may prefer to retain their investment interest to remain anonymous. Alternatively, smaller institutions may be interested in being a lead institution while gaining revenues from a healthy lending market.

The Federal Reserve Board has created limits on loan participations to address concerns that loan participations create concentration risks. These limits are meant to provide the appropriate balance between mitigating risk and encouraging the growth of the industry. Further, the Board will consider the feedback from commenters and determine whether a more stringent cap on single originator loan participations is appropriate.

Limitations on loan participations are a necessary step to protect buyers. Loan participations are a good strategy for credit unions and banks that want to diversify their loan portfolios. This will allow them to maximize their earnings while distributing their risk over several different industries. 


Issues with loan participations made to multiple parties

Loan participations require quality partners and resources. While they spread the risk among multiple parties, they can also be riskier than traditional lending. In some cases, the larger the loan, the larger the losses will be. For these reasons, lenders should carefully consider loan participations before committing to them.

Some commenters have argued that loan participations do not pose systemic risk to NCUSIF, but others maintain that they could increase overall risk exposures if the proposal is implemented. Others have raised concerns that the proposal would undermine the dual chartering system. In addition, several commenters suggested that the rule should remain governed by state law, not federal regulation.

Loan participations made to multiple parties have been used for decades as a valuable tool in commercial lending. These agreements allow banks to participate in transactions by purchasing interest in the loans. This allows them to meet lending limits and diversify their lending markets. However, there are many potential issues with multi-party loan participations.

Loan participations commonly include a Last-In-First-Out (LIFO) or First-In-Last-Out (FILO) structure. Prior to 2009, these structures were used by lead banks as a way to facilitate sale of loan participations. However, these prior accounting variations do not comply with current regulations that require loan participation ownership to be structured on a pro-rata basis.

In conclusion, loan participations offer many benefits to both originators and participants, but they do require up front investigation and ongoing monitoring to ensure they are successful for all parties involved. The best way to select a loan to invest in is to start small and work it into your overall balance sheet strategy and select an originating bank with a good, reliable history.