The revised CRA regulation requires that an institution report small business and small farm loan renewals, refinancings, and extensions as originations(subject to the one per year rule). For reporting the aggregate total, the regulation & Q&A do not seem to address whether renewals, refinancings, and extensions of Community Development loans should be included in the total. Am I missing something? Has anyone received an opinion? My bank is regulated by Federal Reserve.

Any opinions or comments expressed are my own.