Okay---when I read this paragraph:
d. Renewals vs. refinancings. Institutions are permitted to collect data on both refinancings and renewals of loans. So no matter how the loan is renewed or refinanced (that is, whether or not it involves the taking of a new note), the transaction is treated as an origination. However, when reporting small business loan and small farm loan data, the institution is permitted to report only one origination (including a renewal or refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted. The key is to program the institution’s loan system to be able to handle properly the automated tracking and reporting of these small business and small farm loan renewals.
it begs the question---if a renewal is only completed through an amendment/extention agreement NOT a new note would that still be CRA? Make the following assumptions: Yes, all renewals are re-underwritten and credit reviewed, yes it qualifies as a small business CRA loan in both years-- the year it was originated and the next calendar year of renewal.
If you can point me to citations or guidance that would be MOST appreciated.