I have a few loans where the original loan amounts were over 1 million and not reportable. Renewals and Refinances have since been done and the new principle amounts are below the 1 million threshold. Are the renewals/refinances cra reportable now that they are below the threshold or are they still not reportable since the original amount was over 1 million?

The renewals, as long as it's 1MM or under, would be reportable.

Each renewal as treated as an origination so as long as the call report codes meet the CRA small business definition, you should report them.

Isn't there a rule about needing new money on renewals for it to count?

No, just an extension of the due date. Even if the new loan amount is less than the original, just report the amount of the note at time of renewal.

Thanks Shasta. I had thought that you were only allowed to report renewals once per year IF new money was given.

If the loan renews more than once per year, or it renews within the same year that it was originated, you only report the renewal if there was an increase. You do this by either 1) reporting the loan once with the total amount of the renewal or 2) reporting it twice with the first amount on the first LAR entry and the amount of only the increase for the second LAR entry.

If the loan originated in 2009 and renewed once in 2010, report the entire renewal amount, regardless of if it increased, decreased, or stayed the same.

Kelsey D - Which date should you use? I realize in the scope of things the date does not matter since only aggregate data is transmitted, but if examiners see discrepancies, they still use that to form opinions and will call us out on it!