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Agencies Issue FAQs on Coronavirus, Community Reinvestment Act Activities
Agencies Issue FAQs on Coronavirus, Community Reinvestment Act Activities
Posted:
May 29 2020
The OCC has released a list of 13 interagency frequently asked questions related to the Community Reinvestment Act and the coronavirus pandemic.
Among other topics, the document clarifies that:
The agencies will consider COVID-19-affected areas under major disaster declarations (including all 50 states, D.C., and certain territories) as disaster areas for CRA purposes for a period extending six months after the disaster declaration is lifted.
Banks will receive favorable CRA consideration for “community development activities that are responsive to community needs and conducted in response to COVID-19.”
A bank may receive CRA consideration for activities in broader statewide or regional areas that include the bank’s assessment areas.
Paycheck Protection Program loans will be considered “particularly responsive” to community needs when made to businesses with gross annual revenues of $1 million or less or to businesses located in low-to-moderate-income geographies or distressed or underserved non-metropolitan, middle-income locales.
PPP loans of greater than $1 million may qualify as community development loans if they also have a primary purpose of community development as defined under the CRA. PPP loans for $1 million or less will qualify as small business loans.
PPP loans to small businesses with gross annual revenues of $1 million or less that create or retain jobs for LMI individuals or LMI locales, or that otherwise meet the economic development “size” and “purpose” tests qualify as community development loans.
Main Street Lending Program loans that meet relevant CRA requirements may receive CRA consideration.
Bank activities to promote housing stability for LMI renters experiencing financial hardship due to COVID-19 “are considered particularly responsive to the unique
challenges presented by the COVID-19 emergency.”
Cashing Economic Impact Payment checks for non-customers at no charge and waiving late fees and overdraft charges are examples of “particularly responsive” services for LMI individuals.
To read more visit:
https://occ.gov/topics/supervision-and-examination/bank-operations/covid-19-information/covid-19-cra-faqs.pdf