We are doing a consolidation loan to an organization which provides affordable housing opportunities to LMI residents. It is a consolidation of three loans which were all originated by our institution and are community development loans. My question is would this loan be considered a community development loan still? We would report it as a CRA loan normally, but can I still report it as a CD loan?

Is the maturity being extended? Is there some benefit to the consolidation (lower rate, better terms)? Refinances, renwals, modifications to extend maturity of CD loans are reported so this would be if reported if that is the case or if there is new money.

If reported, mention any improved terms that help the borrower.