Skip to content
GeoDataVision
Thread Options
#1961373 - 09/11/14 07:51 PM Volunteer Fire Department- Middle Income Area
solbrillante Offline
Member
solbrillante
Joined: May 2011
Posts: 85
If we have some loans at lower rates than usual for volunteer fire departments, would you consider this for CRA credit? The fire departments are NOT located in low-moderate income areas. Instead, the majority are located in an upper-middle income area. The purpose of the loans was for either purchasing a new ambulance or building a new department. I realized that they donít meet the exact definition of the regulation because they are located in higher income areas; however, ultimately, they are for community developments. Any thoughts? Has anyone had any similar situation with other types of institutions: hospital, nursing home, etc.

Return to Top
CRA
#1961378 - 09/11/14 07:57 PM Re: Volunteer Fire Department- Middle Income Area solbrillante
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
Community development has to meet the definitions and loans to benefit middle and upper income areas are not generally community development unless the area happens to be distressed/underserved, or the entity such as your fire department also serves low/middle areas.

These loans are difficult to document/prove even when in an area with low/mod tracts.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1961398 - 09/11/14 08:20 PM Re: Volunteer Fire Department- Middle Income Area solbrillante
solbrillante Offline
Member
solbrillante
Joined: May 2011
Posts: 85
Thank you

Return to Top
#1961490 - 09/12/14 01:56 PM Re: Volunteer Fire Department- Middle Income Area solbrillante
Live&Learn Offline
100 Club
Live&Learn
Joined: Aug 2012
Posts: 241
South
I had a similar situation and examiners did not qualify the loan or donations because we couldn't prove it served specifically LMI people.
_________________________
The worst question is the one that goes unasked.

Return to Top
#1961660 - 09/12/14 06:17 PM Re: Volunteer Fire Department- Middle Income Area solbrillante
solbrillante Offline
Member
solbrillante
Joined: May 2011
Posts: 85
That's what I am afraid of. I can document that there are low income areas within the upper income area, but I don't think it's gonna fly with the regulators.

Return to Top
#1961967 - 09/15/14 03:26 PM Re: Volunteer Fire Department- Middle Income Area solbrillante
Darth HMDA, CRCM, CAMS Offline
Diamond Poster
Darth HMDA, CRCM, CAMS
Joined: Dec 2013
Posts: 1,387
CA
That's a pretty tough one. We have similar types of loans we report as CD's (First responders)but they have been in LMI or distressed areas. We also use HRSA medically underserved areas to support our case when applicable.

I think this would be a tough one to make a case for.
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

Return to Top
#1967285 - 10/06/14 08:07 PM Re: Volunteer Fire Department- Middle Income Area solbrillante
Ryan Yager Offline
New Poster
Joined: Apr 2014
Posts: 21
IL
Here's a good way to think of it. Is the fire department only going to answer calls and put out fires specifically for low income residents? If now, than it most likely isn't going to count as community development.

Return to Top