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#2049813 - 11/16/15 04:41 PM CDL ?
Tennismom Offline
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Tennismom
Joined: Jan 2004
Posts: 778
Business equity line of credit (less than $1,000,000) to non-profit organization, secured by a multifamily residence (transitional housing). The organization contracts with the Federal Prison Bureau and is a reentry residential center that provides housing, food and services that help residents make a transition back into the community.

Is this a CDL? Don't see it as a small business loan as it is secured by a multi-family which is not CRA Reportable. Not HMDA reportable as it is transitional housing. Similar to scenario at this link, https://www.bankersonline.com/forum/ubbthreads.php/topics/1989520/HMDA_purchase_or_CRA_community, however using the Dallas Fed CRA Loan Data Collection Grid I couldn't find a classification for it.

Thanks.

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#2049849 - 11/16/15 05:54 PM Re: CDL ? Tennismom
Pale Rider Offline
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Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
I would report it as a CD loan. You may need to obtain from the nonprofit the average wages or incomes of the men as they are released from prison and then find work. As convicted felons I would be confident their wages are going to be less than $20 an hour on average. Whatever the number is you will compare that to the median family income number for the MSA and you will have evidence this organization is serving primarily LMI.
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Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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