Giving credit where it is--or isn't--due.

Q. We recently changed how our credit line product is booked--posting them with a five-year maturity. The loan documentation contains a provision that there will be an annual review of the credit to decide if the line of credit con continue. The loan officer must re-approve the credit for it

A. The CRA Questions and Answers at [section] 11.42(a)-5 state that a "renewal" extends the term of the loan. So the answer appears to rest with what you mean by "post a five-year maturity" on your loans. If the loan has a five-year maturity as part of the contract, you do not appear to have extended the term in years 1, 2, 3, or 4. However, if you are just internally posting a five-year maturity but the loan states it is due and payable in one year Unless extended upon further credit review, and you actually do the credit review annually, then it likely would be treated as a renewal when you completed your review and decided to extend the loan. However, if you are just doing a review for conditions of default or financial deterioration that might trigger accelerated demand, and otherwise the customer has the loan for five years under its original contract, examiners would probably question treatment of the annual review as a "renewal."