Does anyone have a good guide for what documentation is needed for the different types of community development loans (the evidence that examiners would look for)? I'm specifically looking for something that can be provided to lenders that tells them specifically what documentation they need to request from the borrowers at the time of the loan.

Thanks!

I just created a worksheet that copies the definition right out of the reg. Each description has a checkbox for them to mark it if applies to the loan they are working on. It has made documenting CDLs much easier at my institution because the "reason" they qualify is right there on the worksheet for examiners to see.

ETA: Then we just add documentation that backs up which boxes we checked.

We have a similar form, but its the specific documentation to support the form that we seem to struggle with.

http://www.bankersonline.com/tools/tools.html#CRA

see maybe you can find a form you need here....

I didn't' mean to be flippant up there, every CD loan, investment and service activity is transaction specific. The documentation should support your bank's claim that a community development purpose has been met. What is the community need that has been clearing met by this loan? Does your borrower have a mission statement that identifies it as a community development organization? What kind of methodology is used to verify that a majority of those benefiting from the loan are low-or-moderate-income?

Pale is right, depending on how the loan qualifies for CD credit, your documentation will vary. We always include whether or not the loan is in an Enterprise Zone/Renewal Zone/Empowerment Zone/TIF District/etc. We also always include the FFIEC demographic information (census tract income level).

If the loan is for affordable housing, we include the rent roll or some other documentation of rent rates/etc. If the institution provides services targeted to LMI people, we include information from their website or ask them for information about the programs that benefit LMI populations. Bascially we back up everything we claim with information received from the borrowers. Does that help at all?

Similar to manimal, I also created a "checkbox" sheet using items directly from the Reg. I use this sheet as my cover sheet for additional documentation. At the end of the day, you have to be able to support why a specific box is checked off. I use a similar sheet to document my qualified contributions.

Gather mission statements from websites, get photos of construction projects (to support revitalization claims - before and after is nice), gather newspaper articles about the entity, the project, the donation, etc.

Get documentation from the entity on how funds were used, how they qualify people who use their services/qualify for affordable housing rents, etc.

You need to show:

What is it you are claiming (a service, an investment/donation, a loan)
What category of Community Development it qualifies for
Why it qualifies
Prove it

Would every commercial loan in an enterprise zone qualify as a community development loan just for being in an enterprise zone?

Enterprise zones are "often" established in low-income areas or places that are recovering from disaster, such as a flood or hurricane.

But they don't have to be, so the answer is no. You have to prove up the community development purpose.