We are financing a construction project. The project consists of 6 townhome style (shared wall) SFR.

The builder is receiving a waiver on city imposed development charges if the builder agrees to sell to families with gross household income equal to or less than 100% of the median family income for the MSA. This is a specific program established to encourage homeownership in the city.

The specific CT is a Moderate Income, however is outside of our AA.

Thoughts or citations would be greatly appreciated.

Tiny little bump?

I'd write it up as a CDL. Your examiner should give you credit for it, presuming you've met the needs inside your AA.

Thanks. That was the one sticking point that I'm worried about, but all of our CT in our AA are Upper and there is really not much opportunity for any type of CD.

Include the fact about your AA census tract income level in your Performance Context as well.