File this under "What do you do?"
$2MM participation (we are not lead). Purchase of multi-family housing complex with 184 units. 100% of units are deemed affordable for low- and moderate-income persons under the Universal Living Wage Calculation of Housing Affordability. 50% of the units are below HUD FMR for the area. Current rents will stay in place. Complex is 95% occupied. Borrower tentatively plans to reconstruct 16 units that previously burned down, but this is not part of the loan proceeds and has no set date. There are no plans to increase rents. (Complex is NOT in LMI census tract.)
Since the loan proceeds will not construct the units, improve the units, add units, etc., and the complex has limited vacancy, would you report this as a community development loan? If so, what is the benefit of this loan for LMI persons since the units have always been affordable?
I always struggle with this scenario to prove any new benefit to LMI with this loan. (And BTW, we have the existing loan on the property to the seller. )
Six consecutive "Outstanding" Large Bank CRA Ratings.... and counting.