I would like to take a poll:

Did you report renewals of community development loans in your aggregate total, and if so, did you receive credit for them during your last exam. (Assuming the renewal was not in the same calendar year etc.)

I appreciate any feedback on this.

Data collected in 2001 and
subsequent years. An institution
should collect information about
small-business and small-farm loans
that it refinances or renews as loan
originations. (A refinancing generally
occurs when the existing loan
obligation or note is satisfied and a
new note is written, while a renewal
is an extension of the term of a loan.
However, for purposes of smallbusiness
and small-farm CRA data
collection and reporting, it is no
longer necessary to distinguish
between the two.) When reporting
small-business and small-farm data,
however, an institution may 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.
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.

A Guide to CRA Data Collection and Reporting
Federal Financial Institutions Examination Council
January 2001

Pg.11

Yes, but I'm curious as to whether others are reporting community development loans in the same manner.

I don't see why renewals of Community Development loans should be handled any differently than renewals of small business loans.

I don't either--but I have heard conflicting information about whether examiners will count them or not.

We report renewals of CD loans.

I've heard the same conflicting information Risa so I understand the question.

I report them, and be sure to include the test that Andy reported in my documentation to remind the examiners that this is per their request .

I had a couple in my data integrity exam this go around (fall of 2003). They were approved. I did however make the effort to show that they STILL met the CD guidelines. It's always possible that after a few years they don't, so between the text of Andy's and your proving it's still CD purpose, you should be able to count them in your figures.