I'm positive that I heard somewhere that banks were successfully getting CRA credit for some/certain TDRs they were doing. The problem is that I don't know if that was another bank, an auditor, or an article. Does this sound familiar to anyone and if so, can you point me to supporting evidence?

I tried that during our last CRA exam. The examiner checked with his supervisor, and told me that we could not receive any credit for that under the lending test, but might be able to get some credit for that under the community development test (we are an ISB). However, nowhere in the PE is our activity in this area even mentioned.

We are OTS-regulated. Perhaps the other regulatory agencies take a slightly different view of this.

I don't recall anything in writing. And while not innovative, if you can isolate a portion of your program to serve LMI households or geographies you should be able to sell this as a CD Service.

There is an FAQ regarding modifications in low and moderate income areas and there is the new definition related to neighborhood stabilization programs:

§ll.12(g)(4)(i)—1: What activities
are considered to ‘‘revitalize or stabilize’’
a low- or moderate-income geography,
and how are those activities considered?
A1. Activities that revitalize or
stabilize a low- or moderate-income
geography are activities that help to
attract new, or retain existing,
businesses or residents. Examiners will
presume that an activity revitalizes or
stabilizes a low- or moderate-income
geography if the activity has been
approved by the governing board of an
Enterprise Community or Empowerment
Zone (designated pursuant to 26 U.S.C.
§ 1391) and is consistent with the
board’s strategic plan. They will make
the same presumption if the activity has
received similar official designation as
consistent with a federal, state, local, or
tribal government plan for the
revitalization or stabilization of the low or
moderate-income geography. For
example, foreclosure prevention
programs with the objective of
providing affordable, sustainable, long term
loan restructurings or
modifications to homeowners in low- or
moderate-income geographies,
consistent with safe and sound banking
practices, may help to revitalize or
stabilize those geographies.