For Community Development consideration - participation in a multi-million dollar loan to a hospital management group whose specialty is to buy distressed hospitals that would otherwise close, re-structure and revamp the management of the hospital so that it can stay open. The group does this on a national basis but some of the hospitals are within our AA. The financials for the group show that 35% of revenue is from Medicaid patients, and another 40% from Medicare patients.

Examiner is saying that since we can't show that the majority of the patients are LMI, these Hospitals are not community services for LMI. What's my come-back?

I mean, a hospital can't have a majority of low/mod income patients - how would it stay in business? But if a hospital in an area near low/mod tracts closes down, what are these folks supposed to do for medical care?
Regulations are a poor substitute for ethics.
Just sayin'