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?

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.

Is there any type of revitalization plan for the city you could use? How many LMI jobs does the city employ?

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).

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.