CRA Small business/small farm loan qualification question using a hypothetical example:
Closed-end Commercial and Industrial Loan that gets renewed each year. In 2012 the loan was originated at $5 million (not CRA reportable). Each year, the borrower pays off $1 million and we renew for the outstanding principal balance. In 2013, renewed for $4MM; $3MM in 2014; $2MM in 2015; and $1MM in 2016.
Can we report the loan as a CRA small business loan in 2016 when the renewal amount reached the small business loan amount threshold? Or do we have to base our reporting off the original commitment amounts ($5MM in this case)?
Thanks so much!