A new insight into PPP loans and their potential impact on CRA performance

A new insight into PPP loans and their potential impact on CRA performance

A new insight into PPP loans reveals that it may be easier to substantiate them as qualified community development loans. One of the 4 different definitions of community development under CRA is the "economic development" definition. To be qualified for economic development a PPP loan had to meet the "size" test and the "purpose" test. However, banks were not required to collect the gross annual revenues of a PPP loan borrower and therefore did not have the data to substantiate whether the borrower met the size test. Noted CRA expert Len Suzio points out that all PPP loans had to meet the SBA size standards to be eligible to receive a PPP loan. That heretofore unrecognized fact means that every PPP loan is, ipso facto, qualified under the size test applied for economic development purposes.

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Avsnitt(100)

CRA Shake-Up: How the Regulators' NPR Could Bleed Community Funding

CRA Shake-Up: How the Regulators' NPR Could Bleed Community Funding

Host Len Suzio welcomes Josh Silver of the National Community Reinvestment Coalition to discuss the regulators' Notice of Proposed Rulemaking on the Community Reinvestment Act. The episode focuses on ...

10 Sep 25min

2026 CRA NPR

2026 CRA NPR

In this episode of Compliance 911, Len Suzio and Dean Stockford examine the OCC and FDIC’s newly proposed revisions to the Community Reinvestment Act, focusing on how the rule could reshape bank class...

20 Aug 17min

Recent Regulatory Updates

Recent Regulatory Updates

In this episode of Compliance 911, Len Suzio and Dean Stockford review key banking and compliance developments from June 2026, including new OCC rules affirming federal banks’ authority over real esta...

6 Aug 17min

Community Development Benchmarks

Community Development Benchmarks

In this episode of Compliance 911, Dean Stockford and Len Suzio discuss the OCC’s proposed Community Development benchmarks for CRA performance, focusing on why community development has historically ...

15 Juli 12min

Unpacking FDIC Consumer Compliance 2026 Supervisory Highlights

Unpacking FDIC Consumer Compliance 2026 Supervisory Highlights

In this episode of Compliance 911, Len Suzio and Dean Stockford unpack the FDIC’s 2026 Consumer Compliance Supervisory Highlights, noting that while 98% of FDIC-supervised institutions earned satisfac...

25 Juni 13min

CRA: The Importance of Assessment Areas

CRA: The Importance of Assessment Areas

The episode “CRA: The Importance of Assessment Areas” explains why a bank’s CRA assessment area is one of the most important decisions it makes, because it directly affects both performance results an...

17 Juni 11min

AI Integration Into Compliance

AI Integration Into Compliance

The episode “AI Integration Into Compliance” explains how artificial intelligence is already becoming a practical tool for bank compliance teams as regulatory expectations rise, data volumes grow, and...

10 Juni 13min

CRA: Other Ways in which banks help meet the needs of the community

CRA: Other Ways in which banks help meet the needs of the community

This podcast explains that banks can strengthen their CRA exam performance by presenting additional lending activity that examiners may not otherwise consider, beyond the usual focus on small business...

27 Maj 11min

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