Could we get CRA credit for loan modifications that had deferred payment dates (approx. 3 months) due to COVID, however there was no extension of the maturity date? How would that work?

We are going through our CRA Exam right now, and the FDIC considered our payment deferral plan as part of the performance context as well as innovative and flexible programs.

Thank you, but you cannot actually report them as small business loans, correct?

You don't have a loan. You are deferring a payment. So it won't qualify as a small business loan, no.

ok thank you!

Great to hear that the FDIC is providing credit for those loans. Did you get credit for commercial loans that were given exetension that were only in low or moderate income census tract or did they consider the entire population. Thanks