Skip to content
GeoDataVision
Thread Options
#2124417 - 03/30/17 05:29 PM CD Loans to Towns/Cities in Upper Income Areas
FancyMe Offline
Junior Member
Joined: Dec 2012
Posts: 45
Florida
We have recently provided a small town in FL with loans for police cars, heavy equipment, etc. In reviewing the town, most of the census tracts are UPPER income areas, however, these loans are needed to serve the residents (with no low or moderate income areas). They can not be included on the CRA LAR, and was hoping to obtain some community development loan credit.
Any suggestions or recommendation to write-up for regulator's review?

Return to Top
CRA
#2124473 - 03/30/17 07:27 PM Re: CD Loans to Towns/Cities in Upper Income Areas FancyMe
CRA Padawan Offline
100 Club
Joined: Oct 2008
Posts: 144
Iowa
I think that is a tough one to document that it is primarily serving LMI. This may be one where you do because it is right thing to do and maybe look at purely the marketing benefits but realize that CD credit is not going to be possible on it.

Return to Top
#2124501 - 03/30/17 08:34 PM Re: CD Loans to Towns/Cities in Upper Income Areas FancyMe
RR Jen Offline
Power Poster
RR Jen
Joined: May 2003
Posts: 3,759
Running and riding everywhere ...
Is there any type of revitalization plan for the city you could use? How many LMI jobs does the city employ?
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!

Return to Top
#2124540 - 03/31/17 01:34 PM Re: CD Loans to Towns/Cities in Upper Income Areas RR Jen
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 771
Wouldn't we want to create jobs for LMI, not just retain jobs?

Revitalization plans, typically cover only a portion of a city (blocks, census tracts, etc.) and not an entire town/city. This is a stretch, but what about a FEMA Designated Disaster Area (DDA).

Return to Top
#2124547 - 03/31/17 02:15 PM Re: CD Loans to Towns/Cities in Upper Income Areas FancyMe
RR Jen Offline
Power Poster
RR Jen
Joined: May 2003
Posts: 3,759
Running and riding everywhere ...
I've had examiners accept LMI job retention. As always, I'd rather write it up and have an examiner not take it than not try. I recently had an examiner allow a city water/sewer bond as a CD investment because it did cover the portion of the town that had a revitalization plan as well as the rest of the city which was primarily middle and upper income.
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!

Return to Top