IMO you can still count a Community Development loan from a prior exam as long as it's still on your books.
The fact that the loan is no longer in a distressed area may kick it out though. Is it at least in a Mod or Low income area?
Community Development loans only
count in the year they were originated/booked or renewed and do not
carry over from prior exam periods (even if they are still on the books).
Count the loan in the year that it was in a distressed area. Subsequent renewal(s) when not in a distressed area should not be counted, unless it has a community development purpose that would still qualify the loan for community development.
Have you considered that the federal banking agencies have adopted a twelve-month “lag period” immediately after an eligible census tract is reclassified as no longer meeting the criteria for a distressed or underserved area. This additional time permit banks to plan and carry out activities that show responsiveness to local needs in these qualifying areas. The extended window for CRA consideration also acknowledges that certain loans and investments may require an extended amount of time to put in place.