I am preparing for an exam and somewhat new to this bank, meaning I'm tasked with going through several loans that someone else qualified and trying to requalify them as the examiners have requested additional support on many. I was looking for some clarification on what PPP loans would qualify as community development loans as my predecessor was automatically qualifying all of them. Will they all count just for being PPP and having the purpose of retaining jobs, or is there some other criteria they need to meet? We are OCC regulated by the way. Thank you for any help!

PPP loans may qualify for community development under the economic development and/or revitalization definitions of community development. The revitalization definition is the easiest because any PPP loan in a low- or moderate-income tract or a distressed/underserved non-metro tract will automatically be qualified - if it is >$1 million. Any PPP loan <=$1 million must be reported as a small business loan and will be examined as such unless you are an ISB in which case if you are examined under the ISB CRA exam standards you can elect to have each PPP loan that is qualified as a CD loan treated as either a small business loan or a CD loan for examination purposes.

The second way PPP loans may qualify as CD is under the economic development definition. Under that definition the loan must meet the size test and the purpose test. I've written about this complex way of qualifying in other BOL posts on the CRA section.

Thanks Len, I appreciate the response. I was browsing around and also found a video that I believe you posted. This helps a lot and is also what I suspected