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#2206733 - 02/21/19 08:42 PM Cd loan: Veteran's clinic
CRA Padawan Offline
100 Club
Joined: Oct 2008
Posts: 144
Iowa
We are financing the tenant improvements for our borrower. The tenant is going to be a Veteran Clinic. How might we obtain documentation that qualifies this loan when the government is not our borrower? What would be sufficient documentation to qualify this as a Community Development loan to LMI? Our loan officer seems to think that simply being for the Veteran's Clinic should qualify it as a loan to LMI. I would think though I would need some form of documentation but I am not sure what to get or how to go about getting it. Any guidance is greatly welcomed.

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#2206752 - 02/21/19 10:17 PM Re: Cd loan: Veteran's clinic CRA Padawan
mrogersfib Offline
100 Club
Joined: Aug 2018
Posts: 116
The key to CRA when developing our lenders is to let them know that they have to be blind to all other factors besides income. Just because the morality of helping veterans feels as community development it is not so under CRA. What we have to look for is if the majority of their patience receive Medicaid if you want to go the community services route. Look to see if the hospital has a community assessment, and only focus on the financial nature of their clientele.

If you want to go the revitalization/stabilization route then you can take a few paths. First is finding out whether or not the loan will attract more residents to the area as I know that most veterans strongly prefer to use VA hospitals, and will travel or move to be closer to one. So are there a lot of low- to moderate-income tracts nearby, does the city have a redevelopment plan that mentions helping the clinic, or expanding the clinic. Another route you could venture down is that the loan will allow the VA Clinic to hire more employees.

Quote:

§ll.12(t)—4: What are examples of qualified investments?
Facilities that promote community development by providing community services for low- and moderate-income individuals, such as youth programs, homeless centers, soup kitchens, health care facilities, battered women’s centers, and alcohol and drug recovery centers;...

§ll.12(g)—4: Can examples of community development activities discussed in a particular Q&A also apply to other types of community development activities not specifically discussed in that Q&A if they have a similar community development purpose?
A4. Yes.

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#2208667 - 03/13/19 06:33 PM Re: Cd loan: Veteran's clinic CRA Padawan
CRA Padawan Offline
100 Club
Joined: Oct 2008
Posts: 144
Iowa
Medicaid was the route I was going to see if we could go to qualify this loan. Thanks.

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