We are undergoing a CRA Exam. We have been documenting Municipal Investments that are in low to mod areas.
For example, a bond with the purpose say water and sewer improvements, new roads, etc.
If the location is in a county with majority low to mod or middle distressed geographies - we have been adding those to our list of CRA investments thinking the improvements would revitalize/stabilize.
The examiners are saying this would not chin the bar because its not specifically in an official revitalization zone - or the bond is not part of a state revitalization program.
I know the rules are changing but was thinking we had gotten credit for this type of instrument in the past.
Should we get credit for this?