CRA COVID FAQ 2: Length of Consideration for Responsive Activities
Question 2 How long will the agencies grant consideration for activities that revitalize or stabilize COVID-19 designated disaster areas? Response 2 The March 19, 2020, Joint Statement(3) indicates that it is effective through the six-month period after the national emergency declaration is lifted, unless extended by the agencies. With specific reference to COVID-19 related revitalization and…
CRA COVID FAQ 3: Consideration of Responsive Activities in CRA Examinations
Question 3 How will activities undertaken in response to COVID-19 that are responsive to community needs be considered in CRA examinations? Response 3 In light of the declaration of a national emergency, and consistent with the Joint Statement, the agencies are clarifying that banks will receive favorable CRA consideration for community development activities that are…
CRA COVID FAQ 4: Consideration of Responsive Activities on a Nationwide Basis
Question 4 Can a bank receive consideration for activities related to the COVID-19 emergency and that are conducted on a nationwide basis? Response 4 The COVID-19 emergency has had a significant health and economic impact that extends beyond many banks’ assessment areas. Banks that are responsive to community development needs and opportunities in their assessment…
CRA COVID FAQ 5: CRA Eligibility of Paycheck Protection Program (PPP) Loans
Question 5 Are bank loans made under the Paycheck Protection Program (PPP) eligible for CRA consideration? For PPP loans that are eligible community development loans, what is the appropriate community development purpose? Response 5 Generally, loans, including PPP loans, in amounts of $1 million or less to for-profit businesses, or to nonprofit organizations that are…
CRA COVID FAQ 6: Reporting of Paycheck Protection Program (PPP) on Call Reports
Question 6 How should PPP loans be reported on Call Reports? Repsonse 6 PPP loans are Small Business Administration (SBA) 7(a) loans. Banks should follow Call Report requirements for reporting PPP loans based on the loan type, amount, and collateral, as applicable. Originally published in the “Community Reinvestment Act (CRA) Consideration for Activities in Response…
CRA COVID FAQ 7: Reporting of Paycheck Protection Program (PPP) Loans as Small Business Loans on the CRA Loan Register
Question 7 For PPP loans reported as small business loans (Type 01), with loan amounts of $1 million or less, made to an existing bank customer, should a bank report revenue on the CRA loan register based on what it had previously gathered about that business? For a new PPP borrower, which has an unknown…
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…