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?
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?