I am probably the only person who does not know the answer to this question, but, we are a bank that went the route of small bank, temporary large bank, now intermediate small and I have no previous CRA experience. Considering the importance of community development, would someone please provide additional clarification on CD loans. I have studied everything available, but do not recall seeing anywhere if there is a magic loan origination date involved...are all loans in the portfolio reviewed for CD credit regardless of when they originated, or, do we only consider loans that originated after the last exam, or, those in the current year? Thanks.

We are nearing the end of our ISB exam. To receive credit for your next exam the origination date would be within the exam period. Mention should be made for those CD loans made previous to the exam date that are still on your books. Also if you have qualified CD loans within your assessment area, you can also earn credit for CD loans made outside your assessment area.

Thank you for the clarification.