[Evelyn]

When the FDIC puts out an FIL regarding “Supervisory Practices Regarding Depository Institutions and Borrowers Affected by XYZ Tropical Storm in Areas of XYZ State,FIs may receive CRA consideration for community development loans, investments or services that revitalize or stabilize federally designated disaster areas in their assessment areas or in the states or regions that include their assessment areas.

If an institution grants a business loan less than $1 million to a business in a disaster region related to a particular FIL such as noted above, is the loan automatically considered a “Community Development” loan for CRA reporting or does it still get reported as a “loan to small business” on the Bank’s LAR?

[jholzknecht]

The loan cannot be reported in your CRA data submission as a community development loan if it is otherwise reported as a small business loan.

[Evelyn]

Understood. But can they elect to report as a CD loan because of the FIL even though it’s less than $1 Million?

[Author]

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