Q: CRA Affordable Housing. The Joint Statement on CRA Consideration for Activities in Response to COVID-19 did not include a reference to affordable housing. Will examiners consider bank activities that help to maintain affordable housing for low or moderate-income individuals, including homeowners or renters, as responsive to community needs during the COVID-19 emergency?
A: Yes. Community development under CRA includes activities that promote affordable housing, including single-family and multifamily rental housing, for low- or moderate-income individuals or families. Activities that promote housing stability for low- or moderate-income renters who are experiencing financial hardship due to COVID-19 are considered particularly responsive to the unique challenges presented by the COVID-19 emergency. These activities include loan forbearance, reduced payments, loan modifications, or restructuring debt for residential rental property owners who in turn agree to offer rent relief to and suspend evictions for low- or moderate-income renters.24 In addition, investments in or grants to intermediary organizations that provide housing support for low- or moderate-income individuals are considered responsive to community needs.
Additionally, as the Joint Statement indicates, activities that promote stability for low- or moderate income homeowners who are experiencing financial hardship due to COVID-19 are also considered particularly responsive to the unique challenges presented by the COVID-19 emergency. These activities include loan forbearance or loan modifications for low- or moderate-income homeowners. These activities will receive favorable consideration when retail lending is evaluated.
All activities must be undertaken in a manner consistent with safe and sound banking practices and applicable consumer protection laws.
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.