Common sense would have me think that similar to CDL or investments(based on the 2009 Q and A), you should receive pro rata credit for the percentage of LMI (as defined by the CRA) borrowers receiving loans through the MyCommunityMortgage program. However until the jury comes back, you may want to
"continue to present such loans to examiners as ‘‘other loan data.’’".
Did I say "common sense" and "examiners" in the same post?