Hello. This may seem like a silly question, but I want to confirm my thinking is correct. We have employees that review loans to determine if loans are eligible for CRA consideration. Those employees sometimes do not receive the loan information until months after the loan actually closed. If the income limits changed between the time of the loan closing and the time of loan review, can the reviewer use the new limits, or should they always use the income limits for when the loans closed?

You use the income limits for the time period in which the loan falls. This means checking on loans processed earlier in the year once the limits are updated.

Thank you