Regarding CDLs - for large bank exams I know that if the loan is reported on the SBR or HMDA then you cannot get CDL credit for it. I just ran across old CDL worksheet that includes the following - is this correct?
Is the loan a small business, small farm, consumer, or home mortgage loan (except for multi-family housing)? ____ Yes ____ No. If no, go to 4. If the answer is yes and the bank is NOT being examined as an intermediate small bank, STOP. The loan cannot be reported or considered in the evaluation as a community development loan. However, the loan’s effect may be included in the narrative section of the PE; keep in mind that the bank has already received positive consideration under another part of the CRA evaluation for this loan.
If the answer is yes and the bank is being examined as an intermediate small bank, the bank has the option for the loan to be considered as a community development loan. If the bank has requested the loan be considered as a community development loan, then go to 4. If the bank has NOT requested the loan be considered as a community development loan, STOP.