Are modifications or extensions to loans reportable for CRA? It is hard for us to distinguish between modifications and renewals because a date is entered in the 'Renewal Date' field in our system for each. We have some that are listed on CRA and some that are not right now.

Any help would be greatly appreciated.

Extensions are reportable as new originations, and have been since 2001. You're going to need to distinguish between the two in some way because you obviously have an internal data integrity issue that is going to be a problem in your next exam.

If you have errors of over 5% or if the examiner is in a bad mood you can be asked to scrub and resubmit your CRA LR. What percent of your LR would these extensions meet if you look back a few years? Fix it for this year, but consider going back and resubmitting the years you haven't been examined on if it's over or close to the threashold. Resubmission on a voluntary basis is easy. Resubmission with a full scrub is a night mare of costs!

Thanks, Dawnie. Since 2001, there have only been a few that we have not included. These were payment deferrals not extensions. We have included all loan extensions. I don't think they make up that large of a percentage because most are done because in most cases renewals are completed.