Hello. We have a number of refinanced (completely new underwriting and new note to replace a termed CD loan) Community Development Loans that our examiner is stating that we should not get credit for on our CRA CD LAR.

Does anyone know if these count or not? I have been researching but haven't found anything specific yet....

OK, found my own answer in the Federal Register, and YES, renewed and refinanced CD Loans are to be reported.