Could a line of credit used for working capital to a factory/industrial business be counted as a CRA loan if it is adjacent to a moderate tract even if it is in a middle tract itself?

Or am I stretching it a bit?

Doesn't sound like economic development and job creation....

Doesn't sound like revitalize/stabilize....

May be a stretch, just my opinion....

Ok, maybe a stretch.

If it were new money would that be a little more feasible?

If I have a refinance or renewal of a commercial loan greater than $1MM and the property is in a moderate census tract...could I include that in my community development portfolio???? As far as the analysis, I would just have to make sure that the rents are LMI friendly?

Yes, I would Bec. Argue stabilization of the tract. And yes also on the rents.

Per the Q and A, not all loans in a low- to moderate-income geography have a stabilizing effect. Some loans may provide only indirect or short-term benefits to low- or moderate-income individuals in a low or moderate-income geography. These loans are not considered to have a community development purpose.

What do you mean by "rents are LMI friendly"? Wouldn't that apply only to affordable housing?