Q: Community Reinvestment Act (CRA) Credit. Will all COVID-19 activity count toward CRA, or just those activities directed at LMI individuals and census tracts?
A: The agencies issued the Joint Statement on CRA Consideration for Activities in response to the COVID-19 (FIL-19-2020) (CRA Statement) on March 19, 2020. The CRA Statement discusses categories and examples of activities related to COVID-19 that will be given consideration under the CRA. Those include retail banking services and retail lending activities in a financial institution's assessment areas that are responsive to the needs of low- to moderate-income (LMI) individuals, small businesses, and small farms affected by COVID-19 consistent with safe and sound banking practices. In addition, qualifying community development (CD) activities will receive consideration. These would include CD activities that help to revitalize or stabilize LMI and distressed or underserved non-metropolitan middle income census tracts as well as those that support community services targeted to LMI individuals.
This Q&A was contained in the Frequently Asked Questions for Financial Institutions Affected by the Coronavirus Disease 2019 (Referred to as COVID-19) – As of March 3, 2021 (which may be updated from time to time). This may be found on the FDIC’s website here: https://www.fdic.gov/Coronavirus/faq-fi.pdf.