OK, I have looked through the forums, but haven't found exactly what I am looking for...

Can a bank submit Freddie Mac Loan Mods for CRA credit if the loan mod ONLY extends the terms of the loan to lower the payment?

I am curious if anyone has submitted these before and what kind of information the examiners requested on the loans.

We have a handful of these modifications and I'm not sure what to do with them...

Thanks in advance for any information you all can provide!

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.”

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.

Thank you, Tennismom. That does help.

Did you submit them as a service that the bank provides?

They mentioned this under the Lending Test (HMDA) under Innovative and Flexible Lending Practices. However, before I first answered your question I had to look back at the PE to determine under which test they mentioned this. To me, I would have said the Service Test too.

These could probably fit in several categories, but innovative and flexible lending practices sounds just right. You are taking steps to accommodate borrower's needs.