We have an existing CD loan which clearly qualified as a CDL at inception in 2008. In 2010 we renewed the loan to restructure it and take additional collateral. Does the renewal count as a CDL? I'm wondering about it because the primary purpose of the renewal was not Comm Dev. The renewal was to improve the bank's position.

Thanks for your help!

md, can you provide some details?

Did you simply take on new collateral with no other changes to the loan?

Did you extend the maturity at all?

What is the collateral?

Guidance is in the FAQs for CRA. By restructuring it and taking additional collateral were you resolving an issue and providing a method to continue with the financing, thereby helping the borrower?

.42(b)(2)—5: Should institutions collect and report data about community development loans that are refinanced or renewed? A5. Yes. Institutions should collect information about community development loans that they refinance or renew as loan originations.
Community development loan refinancings and renewals are subject to the reporting limitations that apply to refinancings and renewals of small business and small farm loans. See Q&A §ll.42(a)—5.
.42(a)—5: Should institutions collect and report data about small business and small farm loans that are refinanced or renewed? A5. 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 refers to an extension of the term of a loan. However, for purposes of small business and small farm CRA data collection and reporting, it is not necessary to distinguish between the two.) 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. However, a demand loan that is merely reviewed annually is not reported as a renewal because the term of the loan has not been extended.
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. These two originations may be reported together as a single origination of $20,000.