If the loans are to a municipality that is within a LMI tract or group of LMI tracts or distressed or underserved tracts (many rural towns occupy only a part of one census tract) then I think you have grounds to claim the loan for CD credit and, if the examiner objects, show him/her the PE's that have given such credit for similar circumstances. Interpretations in the field can be inconsistent on issues when there is no official Agency position. However, I wouldn't heavily rely on these loans to get you to a satisfactory rating. Also, sometimes you can get CD credit for an activity that will count toward an outstanding rating only after you have achieved a satisfactory rating based on your other CD activity. This was a point of confusion regarding the Hurricane Relief back a few years ago and the Agencies had to clarify that banks outside those disaster areas could get credit for their efforts but only after they had established that they had satisfied their own AA CD needs.
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