Board of Governors of the Federal Reserve System 

Federal Deposit Insurance Corporation 

Office of the Comptroller of the Currency 

May 27, 2020 (updated March 5, 2021, to add questions 14–18) 

Community Reinvestment Act (CRA) 

Consideration for Activities in Response to the Coronavirus 

Frequently Asked Questions (FAQs) 

Question 1: Are COVID-19 affected states and jurisdictions considered CRA designated 

disaster areas? 

Response 1: The agencies believe that the Coronavirus Disease (COVID-19) national 

emergency raises unique needs for revitalization and stabilization activities 

that differ from those typically undertaken in response to natural disasters 

or other emergencies. The Federal Emergency Management Agency 

(FEMA) has issued major disaster declarations that include assistance for 

emergency protective measures (Public Assistance Category B) for all 50 

states, the District of Columbia, and certain U.S. territories in connection 

with COVID-19. Areas identified for Category B assistance are not 

normally considered designated disaster areas under CRA because of the 

temporary nature of the activities covered under this category of assistance. 

However, the agencies believe that it is appropriate to recognize such 

COVID-19 designated disaster areas due to the circumstances of this 

national pandemic; therefore, the agencies will grant consideration for 

activities that revitalize or stabilize these areas by protecting public health 

and safety,1 particularly for low- or moderate-income individuals, low- or 

moderate-income geographies, or distressed or underserved 

nonmetropolitan middle-income geographies. Examples of qualified 

activities include loans, investments, or community development services 

that support: 

• Emergency medical care, including medical facility services and 

supplies, temporary medical facilities, and enhanced medical/hospital 

capacity; 

• Purchase and distribution of personal protective equipment; 

• Provision of emergency food supplies; or 

1 https://www.fema.gov/news-release/2020/03/19/coronavirus-covid-19-pandemic-eligible-emergency-protectivemeasures. 
 

 

 

 

 

• Assistance to state, tribal, territorial, or local governments for 

emergency management and to support communications of general 

health and safety information to the public. 

Question 2: How long will the agencies grant consideration for activities that revitalize or 

stabilize COVID-19 designated disaster areas? 

Response 2: The March 19, 2020 Joint Statement (“Joint Statement”)2 indicates that it is 

effective through the six-month period after the national emergency 

declaration is lifted, unless extended by the agencies. With specific 

reference to COVID-19 related revitalization and stabilization activities 

needed to help protect public health and safety during the health 

emergency, as FEMA has issued the major disaster declarations described 

in the Response to Question 1 the agencies believe that a time period of six 

months after any particular disaster declaration is lifted is an appropriate 

time period for consideration of such activities. 

Question 3: How will activities undertaken in response to COVID-19 that are responsive to 

community needs be considered in CRA examinations? 

Response 3: In light of the declaration of a national emergency, and consistent with the 

Joint Statement, the agencies are clarifying that banks will receive 

favorable CRA consideration for community development activities that 

are responsive to community needs and conducted in response to COVID19. Qualifying activities include those that support community services 

targeted to low- or moderate-income individuals, economic development 

by meeting the “size” and “purpose” tests, affordable housing for low- or 

moderate-income individuals or families, or that help to revitalize or 

stabilize low- or moderate-income geographies or distressed or 

underserved nonmetropolitan middle-income geographies. As described in 

the Response to Question 1, qualifying activities also include those that 

help to stabilize COVID-19 designated disaster areas by protecting public 

health and safety, particularly for low- or moderate-income individuals or 

geographies. 

Question 4: Can a bank receive consideration for activities related to the COVID-19 

emergency and that are conducted on a nationwide basis? 

Response 4: The COVID-19 emergency has had a significant health and economic 

impact that extends beyond many banks’ assessment areas. Banks that are 

responsive to community development needs and opportunities in their 

assessment areas will receive favorable consideration for community 

2 https://www.federalreserve.gov/supervisionreg/caletters/CA%2020-4%20Attachment.pdf; 

https://www.fdic.gov/news/news/financial/2020/fil20019a.pdf; https://occ.gov/newsissuances/bulletins/2020/bulletin-2020-19.html.
 

 

 

 

 

 

 

 

 

 

 

development activities located in a broader statewide or regional area that 

includes the banks’ CRA assessment area(s). Banks that are responsive to 

needs and opportunities in the broader statewide or regional areas that 

include bank assessment areas may also receive consideration for activities 

outside those broader statewide or regional areas provided that those 

activities help to revitalize or stabilize COVID-19 designated disaster areas 

by protecting public health and safety as described in the Response to 

Question 1. Activities that benefit low- or moderate-income individuals or 

geographies, distressed or underserved nonmetropolitan middle-income 

geographies, or small businesses and small farms will be considered 

particularly responsive. 

Question 5: Are bank loans made under the Paycheck Protection Program (PPP) eligible for 

CRA consideration? For PPP loans that are eligible community development 

loans, what is the appropriate community development purpose? 

Response 5: Generally, loans, including PPP loans, in amounts of $1 million or less to 

for-profit businesses, or to nonprofit organizations that are secured by 

nonfarm, nonresidential real estate, are reported and considered as small 

business loans under the applicable retail lending test. PPP loans will be 

considered particularly responsive if made to small businesses with gross 

annual revenues of $1 million or less or to businesses located in low-or 

moderate-income geographies or distressed or underserved 

nonmetropolitan middle-income geographies. Participation in such loan 

programs could also receive consideration as innovative or flexible lending 

practices. 

PPP loans in amounts greater than $1 million may be considered as 

community development loans if they also have a primary purpose of 

community development as defined under the CRA. Generally, loans to 

small businesses with gross annual revenues $1 million or less that create 

or retain jobs for low- or moderate-income individuals or in low- or 

moderate-income geographies, or that otherwise meet the economic 

development “size” and “purpose” tests, qualify as community 

development loans. Such loans may also qualify if they help to revitalize 

or stabilize low- or moderate-income geographies or distressed or 

underserved nonmetropolitan middle-income geographies. 

Question 6: How should PPP loans be reported on Call Reports? 

Response 6: PPP loans are Small Business Administration (SBA) 7(a) loans. Banks 

should follow Call Report requirements for reporting PPP loans based on 

the loan type, amount, and collateral, as applicable. 

Question 7: For PPP loans reported as small business loans (Type 01), with loan amounts of 

$1 million or less, made to an existing bank customer, should a bank report 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

revenue on the CRA loan register based on what it had previously gathered about 

that business? For a new PPP borrower, which has an unknown revenue, may 

banks use a revenue estimate and report it as having gross annual revenues of “1” 

(gross annual revenues of $1 million or less) or must they use a CRA revenue 

code of “3” (unknown/not used in credit decision). 

Response 7: Generally, a bank should rely on and report the gross annual revenues that 

it considered in making its credit decision. Loans for which the bank did 

not collect revenue information may not be included when evaluating a 

bank’s performance in lending to businesses and farms with gross annual 

revenues of $1 million or less unless the small business or small farm 

provides supplemental information or the bank has another source 

demonstrating the borrower’s revenue, such as information on existing 

customers. Banks that have access to an applicant’s gross annual revenue 

information may, but are not required to, report that information. When 

evaluating CRA performance, the agencies will take into account the 

unique circumstances affecting borrowers and banks resulting from the 

COVID-19 emergency and will not penalize a bank for making a large 

volume of loans for which gross annual revenue information is not 

available. The agencies will also take into account a bank’s good faith 

efforts demonstrably designed to support low- and moderate-income 

individuals and small businesses and small farms and its efforts to comply 

with applicable consumer protection laws. 

Question 8: How will PPP loans be considered when evaluating the borrower and geographic 

distribution of loans and the distribution of loans inside and outside of bank 

assessment areas? 

Response 8: PPP loans in amounts of $1 million or less will be considered when 

evaluating a bank’s performance under the applicable retail lending test. 

This includes the evaluation of performance based on the distribution of 

loans inside and outside of its assessment areas, by business size based on 

gross annual revenues, and across geographies of different income levels. 

The agencies understand that this current environment presents unique 

challenges. Therefore, although performance may appear to be negatively 

affected, for example by a high level of out-of-assessment area lending, 

examiners will consider the information in context and evaluate it 

accordingly. That said, banks should continue to seek to meet the credit 

needs of their communities if making a significant amount of loans outside 

of their assessment areas. 

Additionally, an examiner’s review of the borrower distribution of retail 

lending is typically focused on activities within a bank’s assessment 

area(s). However, as noted in Q&A __.22(b)(2) & (3)—4,3 a bank may 

receive consideration for retail loans to low- or moderate-income 

3 See Interagency Questions and Answers Regarding Community Reinvestment, 81 Fed. Reg. 48506 (July 25, 2016). 
 

 

 

 

 

individuals, small businesses, or small farms outside of their assessment 

area(s), provided that they have adequately addressed the needs of 

borrowers within their assessment area(s). 

Question 9: Are bank loans made under the Main Street Lending Program eligible for CRA 

consideration? 

Response 9: A bank may receive CRA consideration for Main Street Lending Program 

loans that meet relevant CRA requirements. Specifically, small business 

loans, including Main Street Lending Program loans, in amounts of $1 

million or less to for-profit businesses, or to nonprofit organizations that 

are secured by nonfarm, nonresidential real estate, are reported and 

considered as small business loans under the applicable CRA retail lending 

test. Main Street Lending Program loans will be considered particularly 

responsive if made to small businesses with gross annual revenues under 

$1 million or to businesses located in low-or moderate-income geographies 

or distressed or underserved nonmetropolitan middle-income geographies. 

Such loan programs could also receive consideration as innovative or 

flexible lending practices. 

Main Street Lending Program loans in amounts of greater than $1 million 

may be considered as community development loans if they also have a 

primary purpose of community development as defined under CRA. 

Generally, loans to small businesses with gross annual revenues of less 

than $1 million that create or retain jobs for low- or moderate-income 

individuals or in low- or moderate-income geographies, or that otherwise 

meet the economic development “size” and “purpose” tests, qualify as 

community development loans. Such loans may also qualify if they help to 

revitalize or stabilize low- or moderate-income geographies or distressed or 

underserved nonmetropolitan middle-income geographies. 

Question 10: The Joint Statement 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? 

Response 10: 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 COVID19 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.4 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.5 

All activities must be undertaken in a manner consistent with safe and 

sound banking practices and applicable consumer protection laws. 

Question 11: Will job loss or loss of income due to the COVID-19 emergency be considered 

when determining whether an individual or family is considered to be low- or 

moderate-income? 

Response 11: CRA encourages activities that benefit low- or moderate-income 

individuals and families. This includes individuals and families who have 

recently become low- or moderate- income due to lost jobs, decreased 

hours, or furloughs that will reduce income due to the COVID-19 

emergency. 

Question 12: What retail banking service activities will be considered particularly responsive 

to the needs of low- and moderate-income individuals due to the COVID-19 

emergency? 

Response 12: As the Joint Statement explains, the agencies encourage banks to work 

with affected individuals and communities, particularly those that are lowor moderate-income. Examples of services that are considered particularly 

responsive to the needs of low- or moderate-income individuals include 

cashing federal government stimulus checks at no cost to non-customers or 

waiving late fees and customer overdraft charges. 

Question 13: The Joint Statement highlights loans, investments, and services that support 

access to health care for low- and moderate-income individuals and communities. 

4 Suspension of evictions for tenants would cover instances involving non-payment of rent related to financial 

hardship caused by the COVID-19 emergency and instances involving evictions already in process prior to the 

emergency. 5 An intermediate small bank that is not a Home Mortgage Disclosure Act reporter would have the option to submit 

for consideration home mortgage loans with a primary purpose of providing affordable housing for low- or 

moderate-income individuals as a community development activity. 
 

 

 

 

 

 

Are there other community services that are particularly responsive to the needs 

of low- and moderate-income individuals during the COVID-19 emergency? 

Response 13: Examples of community services that are responsive to the needs of lowand moderate-income individuals due to the COVID-19 emergency include 

but are not limited to: 

• Childcare for low- or moderate-income essential workers; 

• Food banks; 

• Shelters or programs for individuals facing homelessness or 

domestic violence; 

• Alcohol or drug recovery programs; or 

• Utility assistance programs. 

Question 14: Can banks receive CRA service test consideration for processing PPP or other 

pandemic-focused loan applications and related servicing activity? (new FAQ 

added March 5, 2021) 

Response 14: The CRA regulatory criteria for the service test do not include loan 

processing and servicing activities for retail loans originated by a bank.6 

Additionally, 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 PPP 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. 

Question 15: Should banks report, and should examiners give CRA consideration to, PPP 

loans that have been rescinded or returned under the SBA’s safe harbor? (new 

FAQ added March 5, 2021) 

Response 15: 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. 

Question 16: Are PPP loans in amounts greater than $1 million that are also in low- or 

moderate-income geographies or in distressed or underserved nonmetropolitan 

middle-income geographies automatically considered to be community 

development activities? (new FAQ added March 5, 2021) 

6 The retail service test criteria include the current distribution of branches, the bank’s record of opening and closing 

branches, the availability and effectiveness of alternate systems for delivering retail banking services, and the range 

of services provided. See 12 CFR __.24(d) for details. 
 

 

 

 

 

 

Response 16: Yes, a PPP loan in amounts greater than $1 million in one of these 

geographies will be considered an eligible community development 

activity. Pursuant to the Interagency Questions and Answers Regarding 

Community Reinvestment,7 activities that revitalize or stabilize a low- or 

moderate-income geography or a distressed or underserved 

nonmetropolitan middle-income geography help to attract new, or retain 

existing, jobs, businesses, or residents. The PPP was enacted and signed 

into law in order to support smaller businesses and retain jobs. 

Question 17: Due to the economic distress caused by the COVID-19 pandemic, some banks 

have been: (a) waiving withdrawal penalties on certificates of deposit (CDs); (b) 

fulfilling early distribution requests regarding individual retirement accounts 

(IRAs); (c) allowing draws on home equity lines of credit (HELOCs) during the 

repayment periods; (d) increasing transaction limits; (e) eliminating overdraft 

fees; and (f) eliminating ATM fees. Will CRA community development service 

credit be given for these types of actions during the pandemic? How should 

banks document these activities and the number of customers served by 

them? (new FAQ added March 5, 2021) 

Response 17: The Joint Statement on CRA Consideration for Activities in Response to 

COVID-19 (Joint Statement) on March 19, 2020, explains that the agencies 

will provide favorable CRA consideration to retail banking services and 

retail lending activities in a bank’s assessment area(s) that are responsive to 

the needs of low- and moderate-income individuals, small businesses, and 

small farms affected by the pandemic and that are consistent with safe and 

sound banking practices. The Community Reinvestment Act (CRA) 

Consideration for Activities in Response to the Coronavirus Frequently 

Asked Questions (FAQs) include additional examples of such activities. 

The waiving of ATM fees, overdraft fees, and early withdrawal penalties 

on CDs are examples of retail services considered responsive to the needs 

of low- and moderate-income individuals as explained in the Joint 

Statement. The waiving of a bank’s withdrawal fees on savings accounts is 

not included in the Joint Statement or other of these FAQs, but is another 

example of a responsive service. Allowing a low- or moderate-income 

individual to make draws from a HELOC during the repayment period 

could constitute a flexible lending practice. On the other hand, allowing a 

low- or moderate-income individual to make a withdrawal from an IRA, as 

allowed under the CARES Act,8 or to draw on a HELOC during the draw 

period are routine banking services and, as such, are not eligible for CRA 

consideration. 

7 See https://www.ffiec.gov/cra/qnadoc.htm. 

8 See Coronavirus Aid, Relief, and Economic Security Act (CARES Act), https://www.congress.gov/116/bills/hr748/BILLS-116hr748enr.pdf. 
 

Examiners will consider any relevant information a bank provides that 

demonstrates a service is responsive or tailored to the convenience and 

needs of its assessment area(s), particularly the convenience and needs of 

low- or moderate-income individuals. 

Question 18: Considering the challenge of providing in-person community development 

services during the COVID-19 pandemic, how will such services provided 

virtually by bank representatives be considered for CRA purposes? (new FAQ 

added March 5, 2021) 

Response 18: Historically, for CRA purposes, bank representatives have primarily 

provided community development services in-person. However, the 

agencies recognize that the COVID-19 pandemic has limited banks’ ability 

to continue doing so. As an alternative to in-person services, the agencies 

will consider services provided virtually (e.g., Zoom, Microsoft Teams, 

WebEx, etc.) by bank representatives that have a primary purpose of 

community development and that are related to the provision of financial 

services. Examples of community development services provided virtually 

could include, but are not limited to, financial literacy programs or firsttime homebuyer education sessions targeted to low- and moderate-income 

individuals and small business or small farm technical assistance sessions. 

Community development services provided virtually are qualified 

individually, by each event conducted and in consideration of the 

assessment area(s) benefitted. Therefore, if a bank representative conducts 

a financial counseling session to help people affected by COVID-19 

virtually for primarily low- and moderate-income individuals in a single 

assessment area, the bank will receive credit for one community 

development service for the assessment area. Of note, a community 

development service provided virtually that reaches multiple assessment 

areas should be considered at either the state or institution level. For 

example, if a bank representative conducts a small business technical 

assistance session that is virtually attended by businesses nationwide, the 

community development service will be considered at the institution level.