CRA COVID FAQ 8: Consideration of Paycheck Protection Program (PPP) in Lending Distribution Evaluations
Question 8 How will PPP loans be considered when evaluating the borrower and geographic distribution of loans and the distribution of loans inside and outside of bank assessment areas? Response 8 PPP loans in amounts of $1 million or less will be considered when evaluating a bank’s performance under the applicable retail lending test. This…
CRA COVID FAQ 9: CRA Eligibility of Main Street Lending Program Loans
Question 9 Are bank loans made under the Main Street Lending Program eligible for CRA consideration? Response 9 A bank may receive CRA consideration for Main Street Lending Program loans that meet relevant CRA requirements. Specifically, small business loans, including Main Street Lending Program loans, in amounts of $1 million or less to for-profit businesses,…
CRA COVID FAQ 10: Consideration of Responsive Activities Supporting Affordable Housing
Question 10 The Joint Statement did not include a reference to affordable housing. Will examiners consider bank activities that help to maintain affordable housing for low- or moderate-income individuals, including homeowners or renters, as responsive to community needs during the COVID-19 emergency? Response 10 Yes. Community development under CRA includes activities that promote affordable housing,…
CRA COVID FAQ 11: Consideration of Job Loss or Loss of Income in Determination of Low- or Moderate-Income
Question 11 Will job loss or loss of income due to the COVID-19 emergency be considered when determining whether an individual or family is considered to be low- or moderate-income? Response 11 CRA encourages activities that benefit low- or moderate-income individuals and families. This includes individuals and families who have recently become low- or moderate-income…
CRA COVID FAQ 12: Responsive Retail Bank Service Activities
Question 12 What retail banking service activities will be considered particularly responsive to the needs of low- and moderate-income individuals due to the COVID-19 emergency? Response 12 As the Joint Statement explains, the agencies encourage banks to work with affected individuals and communities, particularly those that are low- or moderate-income. Examples of services that are…
CRA COVID FAQ 13: Responsive Community Services
Question 13 The Joint Statement highlights loans, investments, and services that support access to health care for low- and moderate-income individuals and communities. Are there other community services that are particularly responsive to the needs of low- and moderate-income individuals during the COVID-19 emergency?communities. Response 13 Examples of community services that are responsive to the…
CRA COVID FAQ 14: Service Test Consideration for Processing Paycheck Protection Program (PPP) or Other Pandemic-Focused Loan Applications and Loan Servicing
Question 14 Can banks receive CRA service test consideration for processing Paycheck Protection Program (PPP) or other pandemic-focused loan applications and related loan servicing activities? (new FAQ added March 8, 2021) Response 14 The CRA regulatory criteria for the service test do not include loan(7) processing and servicing activities for retail loans originated by the bank….
CRA COVID FAQ 15: Reporting of Rescinded or Returned Paycheck Protection Program (PPP) Loans
Question 15 Should banks report, and should examiners give CRA consideration to, PPP loans that have been rescinded or returned under the SBA’s safe harbor? (new FAQ added March 8, 2021) Response 15 No. Banks should neither report these loans on their CRA loan register nor will examiners consider the loans in their CRA evaluations…
CRA COVID FAQ 16: Community Development Eligiblity of Paycheck Protection Program (PPP) Loans in Low- or Moderate-Income, Distressed or Underserved Geographies
Question 16 Are PPP loans over $1 million that are also in low- or moderate-income geographies or in distressed or underserved nonmetropolitan middle-income geographies automatically considered to be community development activities? (new FAQ added March 8, 2021) Response 16 Yes, a PPP loan greater than $1 million in one of these geographies will be considered…
CRA COVID FAQ 17: CRA Community Service Consideration of Fee Waivers and Other Account Accommodations
Question 17 Due to the economic distress caused by the COVID-19 pandemic, some banks have been: Will CRA community development service credit be given for these types of actions during the pandemic? How should banks document these activities and the number of customers served by them? (new FAQ added March 8, 2021) Response 17 The Joint…