I think I have a CD loan but wanted to run it past a few experts to ensure that I have all the documentation that I need.
Loan of $3.5 million to indian tribe to purchase a software developement company. The company will be established as an 8a and MBE qualified business as a tribal corporation. The tribe is not in our AA but is in the state so, I think that we can definitely use the broader AA arguement.
Business will provide susbstantial non-gaming revenues for the tribe and within 10 years it is anticipated that 100% of the employees will be tribal members. This will provice a substantial oppoprtunity to groom the tribes young people for management positions and allow them to stay on or near the reservation.
Anything else that I need for this?

What is the income level of the tribe? Just serving native groups is not enough to qualify. I do an awful lot of 8A work, but don't take credit for all of it. You need to justify the need for the income and the revenue stream back to the tribe. (IE the corp will funnel the profits back in the form of infrastructure improvements, dividend payments, whatever).

You can easily use the "broader statewide" line if you can show the need (LMI value). I do it all the time. But, you have to also be meeting the needs within your AA to get that credit, so be sure those ducks are in a row.

On the credit side, do they have their 8A yet? They're getting harder to get now a days, so we like to see the certification first, before going too far down the credit structure line.

Thanks for the reply Dawnie. Where do I find breakdowns for tribal income. I have the financials here, but I have no idea what income level would qualify for CRA purposes.

Darn internet...I answered but it didn't post

Anyhoo, geocode the tribal land (should be one or a few tracts) and if it's LMI you're covered. Be sure it's an isolated area or areas (normally tribal lands will not be in a tract with non-tribal, I believe reservations are always seperate tracts...if this is a reservation). I think only Alaska and Hawaii are different when it comes to tribal land and tracts.

If the tract/s are LMI you're ok, but I personally would take the second step and confirm the percentage of shareholders or tribal members living on the reservation as well. You can do this by calling the tribe. (I'd have the lender do it if you are uncomfortable with the terminology). They have this data in their NAHASDA data as well as their IHP.