Success by JazE Edutech / Resource Kit
Resource Kit
Walk a PPP loan file through both CRA outcomes — reportable small business lending or community development financing — with worksheets and exam-ready checklists.
A Paycheck Protection Program loan is not locked into a single CRA outcome: a file that meets the small business loan reporting criteria is reported and considered as small business lending, while a loan targeted to low- or moderate-income geographies or borrowers can be documented as community development financing. Which outcome applies is decided from the loan file, so treatment follows the documentation.
Full written guide, sources, and FAQs
A decision worksheet, exam-file checklist, and note templates that walk a single PPP loan file to one of two CRA outcomes — reported small business lending or documented community development financing.
This resource helps readers connect how are PPP loans treated under CRA to classroom practice, standards-aware implementation, and responsible next steps for schools and sponsors.
This kit is written for bank CRA officers, small business lending teams, and internal reviewers who inherited Paycheck Protection Program loan files and now need to explain, in one exam-ready narrative, how each file is treated under the Community Reinvestment Act. It fits institutions that reported PPP originations alongside their regular small business book and want the treatment decided the same way every time.
It also helps lenders still holding forgiveness paperwork, audit trails, and payroll-based size confirmations who want those artifacts working for the CRA file rather than sitting in a separate folder. If your institution partnered with a community development financial institution on targeted PPP-style lending, the community development screen in this kit will matter most to you.
The kit is built around one loan file at a time, because that is the unit an examiner evaluates. You get a dual-outcome decision worksheet that walks the file through two screens, an exam-file documentation checklist, and note templates that connect the loan's call-report record to its CRA data fields. Every artifact prints cleanly and carries its own instructions, so a teammate can pick up a file mid-review without a briefing.
What separates this kit from a general PPP explainer is its single-file treatment fork: rather than sorting the whole PPP book in bulk, it forces one recorded outcome per loan file and assembles the documentation in the order an examiner requests it. That file-by-file discipline is what makes a treatment decision hold up when a reviewer traces it. Success built this kit around the single-file treatment fork so institutions can defend each PPP determination with a documented, repeatable decision.
Start with the program facts: draw type, origination date, the size criterion the borrower met, and where forgiveness stands. Record those on the worksheet first, because every later screen reads from them. Then run the two screens in order — reportable small business lending first, community development financing second.
The Treatment Fork Console is designed to change state as you work. When the Screen A gates check off — borrower revenues within the qualifying range, an original amount at or below the small-business original-amount threshold in effect for the reporting year (adjusted over time under the current framework), and a borrower located in the assessment area — the file's status flips to reported lending data. When the Screen B gates check off instead — low- or moderate-income geography or borrower targeting backed by a primary-purpose rationale — the status flips to a community development financing determination with its own memo. If neither screen completes, the worksheet holds the file at 'program facts incomplete' and names the missing evidence.
Screen A treats a PPP loan like any other small business loan. Under the reporting framework banks have long operated through the CRA regulations at 12 CFR Part 228, small business loan data covers business loans with original amounts at or below the small-business original-amount threshold in effect for the reporting year (adjusted over time under the current framework), made to borrowers with qualifying annual revenues where the institution's reporting framework collects that field, and located inside the assessment area. Confirm the current threshold figure with your primary federal regulator for the submission year in question. A PPP file that meets those criteria is reported in the bank's small business lending data and considered under the lending test. The Loan-File Reportability Checker details how each gate applies by bank type.
Screen B applies when the loan's targeting supports a community development reading. During the COVID-19 response, the Federal Reserve stated in its CRA questions-and-answers guidance that PPP loans to small businesses, including small farms, would be considered favorably in evaluations, and banks documented targeted PPP originations alongside community development narratives. The SBA's program rules — payroll-based eligibility generally limited to businesses with 500 or fewer employees — are the reference point for the borrower-size facts recorded in the file.
The two screens are not stacked. One loan supports one recorded treatment, and the worksheet makes the choice visible so a reviewer can trace it. Program-level totals, tracked separately in the log, let a bank discuss its full PPP response without implying that a single loan was presented two ways.
A PPP treatment is only as strong as the file behind it, because the determination lives in documentation rather than in the loan system alone. Use this checklist to assemble one folder per outcome, ordered the way an examiner is likely to request it, and keep the worksheet's recorded status as the folder's cover note so the treatment is legible before a single page is turned.
The companion to this kit is the Loan-File Reportability Checker, which screens general small business loans for CRA reportability and explains each gate interactively. Run the checker for the reporting-data question, then use this kit for the PPP-specific treatment decision and its documentation. For files leaning toward Screen B, the Primary-Purpose Determination Kit walks the 'primarily for community development' test, and the community development financing test explainer shows how qualifying financing activities are structured and scored at exam time.
This kit is an educational planning resource, not legal, compliance, tax, or investment advice. CRA treatment of any specific loan depends on program facts, your institution's charter and exam framework, the data rules in effect for a given submission year, and examiner review. Reporting thresholds, data fields, and program guidance change over time.
Confirm every determination with your primary federal regulator and your compliance counsel before it appears in a submission or exam file. Community Reinvestment Act treatment is never guaranteed by documentation alone, and no kit, worksheet, or tool can promise an examination outcome or a rating result.
No. A PPP loan enters small business lending data only when the file meets the reporting criteria — qualifying borrower revenues, an original amount at or below the threshold in effect, and a borrower located in the assessment area. The determination is documented, not automatic.
They can, when the loan's targeting to low- or moderate-income geographies or borrowers is supported by a primary-purpose rationale and documented in the file. The kit's Screen B walks that determination step by step.
Yes. The 2020–2021 interagency CRA questions-and-answers issued during the COVID-19 response stated that PPP loans to small businesses, including small farms, would be considered favorably in evaluations. Check the current guidance from your regulator for the framework in effect for your exam.
A loan supports one CRA treatment. Small business lending reported in the lending-test data and community development financing determinations are evaluated as different books, so the same loan file must not appear in both. The worksheet records a single treatment per file, and the separate program-level tracking log keeps totals from implying per-loan double counting.
The program authorization reference, borrower size evidence dated to origination, the borrower's geography record, a dated determination memo, and a reconciliation note matching the call-report record to the CRA data fields. The kit's checklist orders these the way an examiner is likely to request them.
No. It is an educational planning resource. CRA treatment depends on program facts, the rules in effect for your submission year, and examiner review, so confirm determinations with your primary federal regulator and compliance counsel.
Federal Reserve Board
Federal Financial Institutions Examination Council
Office of the Comptroller of the Currency
U.S. Small Business Administration
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