We have a renewal loan that was originally for taking an abandoned property in a low-income census tract and renovating it into part commercial, part residential space. Is a renewal of this loan able to be counted as a community development loan?

What CD definition do you believe applies here? What is your rationale for that? What documentation do you have to substantiate your argument?

Renewals are eligible for CD recognition as long as they are a qualified CD purpose and meet the definition of a renewal.

Not exactly apples to apples, but we had a similar situation with our SBA 504 loans. They received CD credit when they were originated, but when rates tanked a few years ago, everyone refied out of their 504 loans. The loan purpose was the same, but since the loan was no longer a 504, we did not receive credit for the refi, even though the refi benefitted the organization. Cost us about 10MM in CD loans that exam....