I have a hard time believing that a Bank won't get Community Development credit for a loan to build affordable housing just because they decide to do a one-time close, rather than separating out the financing. Putting the grid to the side, it would seem this fits the following Interagency Q & A:
§ll.12(h)—1: What are examples of community development loans? A1. Examples of community development loans include, but are not limited to, loans to
•borrowers for affordable housing rehabilitation and construction, including construction and permanent financing of multifamily rental property serving low- and moderate-income persons;
With that being said, in a situation where a Bank executed separate financing for the construction phase and the permanent phase, does an institution report both and, in essence, get to double count? Doesn't seem right, but I can't find anything concrete regarding an answer one way or another. The Grid and the Interagency Q & A could be interpreted to support both conclusions. Does anybody know of specific guidance on this?