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#2271077 - 06/01/22 02:41 PM PPP Loan Renewal - CRA Reportable?
HMDA CRA Gal Offline
Junior Member
Joined: Sep 2009
Posts: 43
We are seeing some SBA PPP loan renewals come through on our CRA LAR. Are these renewals still considered CRA small business reportable? I can't seem to find any guidance on this. Thoughts are appreciated! Thanks!

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#2271079 - 06/01/22 03:00 PM Re: PPP Loan Renewal - CRA Reportable? HMDA CRA Gal
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
"SBA PPP loan renewals" - these loans are subject to renewal?
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#2271080 - 06/01/22 03:13 PM Re: PPP Loan Renewal - CRA Reportable? HMDA CRA Gal
HMDA CRA Gal Offline
Junior Member
Joined: Sep 2009
Posts: 43
This is my question. Thanks!

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#2271081 - 06/01/22 03:18 PM Re: PPP Loan Renewal - CRA Reportable? HMDA CRA Gal
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
Any small business loan can be reported multiple times if they are renewed or refinanced subject to the once-per-year rule.
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#2271082 - 06/01/22 03:19 PM Re: PPP Loan Renewal - CRA Reportable? HMDA CRA Gal
HMDA CRA Gal Offline
Junior Member
Joined: Sep 2009
Posts: 43
Here is one example: PPP loan originated in May 2020 with a maturity of May 2022. In April of this year, we did a renewal and extended the maturity from May 2022 to May 2025. Is this CRA reportable? Is anyone else seeing PPP renewals?

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#2271083 - 06/01/22 03:25 PM Re: PPP Loan Renewal - CRA Reportable? HMDA CRA Gal
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
From what I remember, if these were not forgiven, then the balance had to be paid off in either 2 years or 5 years, depending on when they were approved. There should be no "renewals". But it has been a while since I looked at the rules. I am not aware there was any balloon payments or other extensions required.
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#2271084 - 06/01/22 03:28 PM Re: PPP Loan Renewal - CRA Reportable? HMDA CRA Gal
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
I believe the first round of PPP loans had a 2-year maturity after which they could be extended for up to a 5-year payoff. But I have not researched this.
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#2272324 - 06/30/22 04:08 PM Re: PPP Loan Renewal - CRA Reportable? HMDA CRA Gal
fmissle Offline
Diamond Poster
Joined: Jul 2007
Posts: 1,016
Pac NW
Reference SOP 50 57 2, 7(a) Loan Servicing and Liquidation.

The maturity date of a PPP loan may be extended for up to 10 years beyond its original maturity date if the extension is granted before the SBA loan guaranty expires (i.e., less than 180 calendar days after the original maturity date) and the extension will aid in the orderly repayment of the loan.

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#2272348 - 06/30/22 08:38 PM Re: PPP Loan Renewal - CRA Reportable? HMDA CRA Gal
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
Based on fmissie's research an extension of the maturity date of a PPP loan could qualifty as a "renewal" for CRA purposes and could be reported a second time as long as the renewal does not occur in the same year the loan was originated.
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