We believe that the modifications to the lines of credit may be counted as new CD loan originations, provided they are not counted more than once per year.

The Interagency Q&As Regarding Community Reinvestment state that institutions should collect and report data about CD loans that they refinance or renew as loan originations. The Q&As also state that refinancings and renewals of CD loans are subject to the same reporting limitations as small business and farm loans. Regarding small business and farm loans, the Q&As state that “an institution may only report one origination (including a renewal or refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted.” The Q&As also describe a renewal as “an extension of the term of the loan.”

Consequently, we believe modifications that extend the maturity dates of lines of credit that qualify as CD loans would be considered renewals that may be reported as originations once per year.

For resources related to our guidance, please see:

• Interagency Q&As Regarding Community Reinvestment, Question .42(b)(2)-5 (July 25, 2016) (“Should institutions collect and report data about community development loans that are refinanced or renewed? A5. Yes. Institutions should collect information about community development loans that they refinance or renew as loan originations. Community development loan refinancings and renewals are subject to the reporting limitations that apply to refinancings and renewals of small business and small farm loans.”)

• Interagency Q&As Regarding Community Reinvestment, Question .42(a)-5 (July 25, 2016) (“Should institutions collect and report data about small business and small farm loans that are refinanced or renewed? A5. An institution should collect information about small business and small farm loans that it refinances or renews as loan originations. (A refinancing generally occurs when the existing loan obligation or note is satisfied and a new note is written, while a renewal refers to an extension of the term of a loan. However, for purposes of small business and small farm CRA data collection and reporting, it is not necessary to distinguish between the two.) When reporting small business and small farm data, however, an institution may only report one origination (including a renewal or refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted. However, a demand loan that is merely reviewed annually is not reported as a renewal because the term of the loan has not been extended.”)