The CDFI Fund considers both bundled and individually purchased loans as eligible Financial Product activity for reporting in the TLR.
When loans are purchased in a bundle from a Certified CDFI, and the purchasing organization includes an OTP – Certified CDFI(s) market component in its Target Market and designates the transaction as having a “Designated Target Market Type” of “OTP-Certified CDFIs”, the entire bundle will be reported as a single Financial Product transaction in the TLR.
If loans are purchased in a bundle from a non-Certified entity—or from a Certified CDFI but the reporting organization does not have an OTP – Certified CDFI(s) Target Market component or does not designate the transaction as having a “Designated Target Market Type” of “OTP-Certified CDFIs”—each loan within the bundle must be reported individually as separate Financial Product transactions.”