In traditional commercial lending, LOC renewals occur annually. Normally, this involves the presentation to the loan committee of updated credit information and a new decision is made to renew or modify the credit. If the credit is not disqualified as CRA reportable for some reason (e.g., LOC over $1 million), the full amount of the line would be reported. Sometimes, the LOC is extended beyond the current annual maturity date because not all the relevant data has been collected and there is inadequate information to make a new credit decision until the data is available. The extension would not be reported. The committee minutes and loan file should clearly document this.
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