We maintain other lending data such as refinances with HARP and HAMP and present to the examiners at exam time.
During the last CRA Large Bank examination, the examiners expounded on this under Innovative and Flexible Lending Practices.
“XYZ Bank has been a very active participant in the Home Affordable Refinance Program (HARP), as well as the Home Affordable Modification Program (HAMP) during the evaluation period. HARP is designed to assist borrowers in obtaining a new, more affordable mortgage after efforts to obtain traditional refinancing have been unsuccessful. Under HAMP, if eligible, a borrower’s loan is modified to reduce their mortgage payment to no more than 31 percent of gross monthly income. XYZ Bank has processed X,XXX applications under HARP and X,XXX applications under HAMP during the evaluation period.â€
Does that answer your question? Present at exam time with the hope the examination team makes special mention of the fact that you are doing modifications to help borrower's lower their monthly payment.