Your previous CRA exam may not have included pandemic activities, but your next one is likely to include activity around the SBA’s Paycheck Protection Program, or PPP. You can get credit for participating in the PPP under your CRA program, which translates into CRA lending performance. Your next exam would highlight your participation in the program, and you would also account for the individual loans that were deployed under the program, either as small business lending performance or community development loan activities.

Here, I share how to classify these PPP loans and how to tell if your PPP loans count as community development loans. I also discuss mining for other community development loans and “hooks”. Make sure to check out the SBA’s guidance on PPP loans, linked below.

Frequently Asked Questions (FAQs) on the Small Business Administration’s Paycheck Protection Program – March 3, 2021: https://www.fdic.gov/coronavirus/smallbusiness/faq-sb.pdf

CRA Today Website: https://cratoday.com/

CRA Hub: https://cratoday.com/hub

Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/

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