We have some interim construction loans that are mostly spec homes. Some of the locations are in moderate census tracts. If the builder is not known for specifically building homes for low and moderate income persons would the bank receive any CRA credit by just the homes being located in a moderate census tract. Remember, most of these are spec homes so there is no income information on the buyer. Thanks.

You would not report the loans under HMDA or CRA if you are securing the loans with the residential real estate. The only way you could possibly get credit imo is if you could show the project is part of a bona fide plan to revitalize or stabilize a LMI area in which case this might be considered to be a community development activity (see new proposed Q&A's). But on the surface, it looks like you will not get any credit for the activity as you described it.