We are reviewing a potential Community Development Loan for a developer to refinance an existing loan to bring to our Bank for a student housing project in a market outside of our assessment area. The property is located in a moderate income area, however in reviewing the rent structures, they are slightly above fair market rents. BUT, the units are mostly 3 bedrooms - where each tenant has a separate lease, pays their individual water and utility bills through separate meters. Would this count as a efficiency or a 3 bedroom unit? The efficiency rents would then be WELL below fair market rent, but as a 3 bedroom combined with 3 separate students with 3 separate leases are above FMR. Any advice?