Q: Should banks report, and should examiners give CRA consideration to, PPP loans that have been rescinded or returned under the SBA’s safe harbor?
A: No. Banks should neither report these loans on their CRA loan register nor will examiners consider the loans in their CRA evaluations of banks during the applicable time period, as these loans ultimately had no impact on the relevant business, its employees, or its community.
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: