We have a commercial loan which has been renewed several times since it originated in 2002. The original amount of the loan was $1,200,000. Since that time every renewal has been for less than $1 Million, with the latest renewal for $165,000.

I have been told that because the original loan amount was over $1 million it is not reportable as a CRA loan regardless of the current loan amount.

Is that correct?

Would this be a community developement loan? or Small business loan?

I report every renewal of a Community Development loan as a CD loan. As an examiner told me each renewal is another credit decision.

For a Small Business loan I would think you could report it for each renewal provided it was under $1 million. Each time a new credit decision is made.

For CRA each renewal is an origination, with the caveat that you report once a year (plus one renewal with new money - in which case you report one loan for the full amount of the first and then the new money on the renewal).

Once you have a new origination of $1 million or less it would be reportable assuming it meets the other requirements to be a small business or small farm loan.

Refer to the FAQs. Search on renewals. Your specific question is not addressed, but you can see the expectation to report renewals as originations.

http://www.ffiec.gov/cra/qnadoc.htm

Thanks for your responses. It was a small business loan.

bb