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#450008 - 10/31/05 04:42 PM CDFIs
golffan Offline
Junior Member
Joined: May 2003
Posts: 32
We have been approached to invest (CD placement) in a CDFI. The mission of the CDFI is to provide services to lmi families, it is located within a lmi area now located in a emergency disaster area, however it is slightly out of our CRA AA. We want to invest to help them out but we also want credit for this. Has anyone invested in a CDFI not located within their CRA AA?

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#450009 - 10/31/05 07:22 PM Re: CDFIs
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Any investment can be counted that is either in your AA, or in a broader statewide or regional area. I have received investment and loan credit for deals outside of my assessment area many times. Basically you need to show that you are meeting the needs of your AA within your performance context, and then stepping outside of the AA to continue to meet the goals of CRA is acceptable.
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Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#450010 - 10/31/05 10:20 PM Re: CDFIs
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
It is a little tricky however, because as Dawnie notes, "you need to show that you are meeting the needs of your AA . . ." before you will get credit for CD outside your AA. So be sure you've got the information to demonstrate this. If you don't have any CD activity inside your AA, be careful to demonstrate there aren't any CD opportunities within the AA performance context (this can be tricky because you can never be certain you haven't overlooked opportunities).
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#450011 - 11/02/05 09:06 PM Re: CDFIs
Anonymous
Unregistered

I am confused, I thought we could get credit for any investment within a CDFI or with an agency located in an emergency disaster area that supports LMI services/families.

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#450012 - 11/02/05 09:18 PM Re: CDFIs
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
You still have to consider your assessment area when trying to take credit for an investment, loan or service. I can't take credit for a donation to an agency that qualifies in New Orleans because it would be in no way related to the community I serve (remember what the C in CRA is for). But I can however take credit for a similar donation in a community within or close to my AA.
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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