I have some very basic questions regarding this association. As far as I understand banks pay a membership fee to belong to this this group. Membership in the group then allows banks the opportunity to invest in Loan Pools on an annual basis. They currently have three pools providing CRA Credit opportunities including the following programs:
Affordable/Low Income Multi‐Family Rental Housing including mixed use properties
Economic Development Loans
Special Needs Housing
My question, are these considered CRA loans , CRA loan Participations or CRA investments under the small-intermediate CRA exam. If loan participations then, these would be considered 'investments' ?

In addition to the three lending pools, the WCRA also offers Private Placement Bond Investments; a Tax
Exempt Investment Program for 501(c)3 nonprofits to provide financing for affordable housing and real
estate based economic development projects. As a member, the WCRA makes these Investment opportunities available to banks. These I am assuming then will fall under the investment test. Is this correct?

In my past life at a different bank, we had funds invested in all 3 pools. As a large bank, they were included in our annual filing, based on the percentage owned at the end of each year, as a consortium loan (consortium is one of the categories in the CRA DES software. They were part of community development lending, and were considered under the lending test, as a large bank.

I don't know, but suspect the bond investments would fall under investments. WCRA always has good reports; be sure to get your credit admin side involved, since they need to assess credit risk. PM me if you want further details.