Re: Important CRA broadcast regarding PPP loans - time is of the essence - brief recorded explanation is available
I have been surprised by the number of banks that have failed to identify, capture and code their PPP loans for CRA purposes, particularly for Community Development and for recognition of "flexible and innovative lending responsive to community needs". Even more shocking is that some banks did not report their large PPP loans for CD purposes in the 2020 annual CRA filing.
The PPP loans are a terrific opportunity to earn Community Development credit under CRA and because they qualify as flexible and innovative as well as complex they can earn you extra credit during a CRA exam.
All banks that participated in the PPP loan program should be certain to capture and compile the PPP loans and to take the extra step of collecting the documentation to qualify those loans for Community Development credit.
Any bank that extended a PPP loan >$1 million should have reported it as community development (make sure you have the documentation to meet the purpose and size tests). If you did not report your large PPP loans as community development I would urge you to consider refiling as soon as possible because generally it's not too late to have your refiled data reflected in the annual public release of the CRA A&D data if you refiled your corrected data by the end of March or the beginning of April.