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CRA Community Development Loan

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A CRA Community Development Loan was included in the last exam cycle for our bank. In 2019 the loan was modified with new money and we added it to the CRA Community Development Loan list again for the current exam cycle. With loan modifications, can we count the total loan amount or just the new money that was added to the original loan?

You'll find the info below in the "CRA Guide to DAta Collection and Reporting."

An institution should collect information about small business and small farm loans that it refinances or renews as loan originations. When reporting small business and small farm data, however, an institution may only report one origination (including a renewal or refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted. If an institution increases the amount of a small business or small farm loan when it extends the term of the loan, it should always report the amount of the increase as a small business or small farm loan origination. The institution should report only the amount of the increase if the original or remaining amount of the loan has already been reported one time that year.

For example, a financial institution makes a term loan for $25,000; principal payments have resulted in a present outstanding balance of $15,000. In the next year, the customer requests an additional $5,000, which is approved, and a new note is written for $20,000. In this example, the institution should report both the $5,000 increase and the renewal or refinancing of the $15,000 as originations for that year.

First published on 06/14/2020

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