Scratching my head on this one. I'm thinking the answer is "no".

When running analysis on the lending test for small business loans, do renewals count toward that goal or only new originations? What about a renewal with new money? By renewal I mean that we are not satisfying or replacing the original obligation.

Thanks,
Norm

Renewals as defined under CRA are extensions of credit in which the maturity date of the underlying note is extended. Those renewals are reported and counted under CRA in their full amount, whether an increase or no change at all, subject to the once per year limit.

Renewals under 1071 are not reported unless there is an increase and then only the amount of the increase is reported. The treatment of renewals is markedly different than under CRA.

Loans purchased and participations are also treated completely differently under both regulations.

Thank you, gentlemen.