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BOL Conferences Top Gun 23
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#2199270 - 11/28/18 04:35 PM Seasonal Housing and CD credit
Lori01 Offline
100 Club
Joined: Jan 2007
Posts: 165
Available housing for seasonal workers in the area of National Parks can be difficult to find. These employees are competing for housing because the available stock is being turned into short-term, high cost vacation rentals.
Of course the Parks Service doesn't have the money to build more housing. In 2014 Congress passed a law giving the National Park Service the authority to partner with private developers to build and manage housing on park owned land. So far, no one has exercised this option. However, a park in our AA is looking at forming one of these partnerships.

My question is: would a loan or investment in this project be considered for CD credit?

The employees would be LMI, but the jobs are only seasonal, but without the housing, the jobs remain vacant. They employee does have to pay rent, not sure how much but I'm sure it's less than the "norm" for the area. The housing would be vacant when the park is simi-closed in winter. The tract is upper income.

Since this is an entirely new program/idea, there's no history I can look to. Just wondering what some of the more experienced folks here think of the chances of CD credit for a project like this? My thought is by providing housing opportunities, we are providing employment opportunities. (FDIC regulated large bank)

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#2206758 - 02/21/19 10:57 PM Re: Seasonal Housing and CD credit Lori01
mrogersfib Offline
100 Club
Joined: Aug 2018
Posts: 116
I would say no because of the short term benefit, and national parks are only "communities" during a portion of the year. Let alone--most banks don't include National Parks in their AAs (raises your inherent risk in the redlining risk charter).

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