Hi,

We have a refinance Commercial Loan over $1million on mixed property-redevelopment property in downtown Kalamazoo area of Michigan. The addres of the mixed property is appartment and local businesse located in a moderate income tract. This is a refinance of a loan originated in 2006 (which was not reported as CD at that time). Can I report this refinance as a CD refinance loan now?

Thanks
Lisa

Refinancing and renewals can be reported as CD loans under CRA. Which definition of CD do you believe applies?

1 Multifamily affordable housing
2 Revitalization/Stabilization

What is your reasoning and what documentation do you have to support your claim?

I don;t have much documentation but note and approval. However would consider more revitalization/stabilization of moderate income tract, also retaining jobs. What other documentation would I need?

Thanks again

If you review prior discussions here on this topic, you will see that you need to provide documentation supporting why and how the loan qualifies for community development:

is the location in a revitalization area
will loan funds finance improvements to the property, therefore improving the area
if affordable housing, information on rents charged and how the determination was made re qualifying as affordable housing
job - number of jobs provided/retained, types of job, salaries, etc.

The bank must support its contention that the loan qualifies as community development.