If we renew a comm line of credit that originally qualified for CRA credit/CD credit, does it qualify for CRA for the new year in which it was refinanced? Thanks!

http://www.ffiec.gov/cra/guide.htm
Page 12
Refinances and Renewals
An institution should collect information about small business and small farm loans that it refinances or renews as loan originations. When reporting small business and small farm data, however, an institution may only report one origination (including a renewal or refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted.
If an institution increases the amount of a small business or small farm loan when it extends the term of the loan, it should always report the amount of the increase as a small business or small farm loan originaorigination. The institution should report only the amount of the increase if the original or remaining amount of the loan has already been reported one time that year.
For example, a financial institution makes a term loan for $25,000; principal payments have resulted in a present outstanding balance of $15,000. In the next year, the customer requests an additional $5,000, which is approved, and a new note is written for $20,000. In this example, the institution should report both the $5,000 increase and the renewal or refinancing of the $15,000 as originations for that year.
However, the institution may report the $5,000 increase together with the renewal or refinancing of the $15,000 as a single origination of $20,000.

Yes, Yes, Yes...as in the instruction above. I am amazed as I find banks that have not been reporting (or presenting in examinations) their renewals/refinances.

I am just not a CRA person...

Thanks both!

The following is from the Interagency Q&As on CRA.

"§__.42—4: Should renewals of lines of credit be collected and/or reported?
A4. Renewals of lines of credit for small business, small farm, consumer, or community development purposes should be collected and reported, if applicable, in the same manner as
renewals of small business or small farm loans. See Q&A §__.42(a)—5. Institutions that are HMDA reporters continue to collect and report home equity lines of credit at their option in accordance with the requirements of 12 CFR part 203."

Q&A __.42(a)-5 pretty much says what was quoted in the post above about page 12 of the CRA Data guide.

TY, RR!

And FYI, I have asked examiners if banks are EXPECTED to report their refinances and renewals (and for CRA, modifications that extend maturity dates) and the answer was yes. It is part of the reporting, not an optional part.

That works for me!