Q: Can banks receive CRA service test consideration for processing Paycheck Protection Program (PPP) or other pandemic-focused loan applications and related loan servicing activities?
A: The CRA regulatory criteria for the service test do not include loan processing and servicing activities for retail loans originated by the bank.7Additionally, the agencies generally consider building new lending platforms and technical assistance provided to borrowers during a loan application process to be activities that banks engage in during the normal course of doing business. Therefore, the agencies will not extend CRA Service Test consideration for PPP-related activities. The agencies do recognize the Paycheck Protection loan program is responsive to community credit needs. Therefore, these activities will be considered under the CRA Lending Test when evaluating flexible or innovative lending programs offered by the bank.
This Q&A was contained in the Interagency “Community Reinvestment Act (CRA) Consideration for Activities in Response to the Coronavirus Pandemic Frequently Asked Questions (FAQs)” initially issued May 27, 2020, and updated March 8, 2021. This issuance may be found here: