I have nothing to add, but do have a scenario i'd like some input on.
Last edited by bcompliance; 04/24/19 06:28 PM. Reason: add bank size
We are an intermediate small bank and have a loan to tear down an existing structure and put up a 80+ room hotel. The gross revenue of the business and loan amount are both over $1,000,000. The property is not in a low-moderate income area. We got this loan through a local county improvement corporation that’s mission statement states that it “serves as the lead economic development agency by advancing, encouraging, and promoting the industrial, economic, commercial, and civic development of this County”. Assuming that this loan will create permanent jobs that are paying low-moderate wages, is this a loan that we should submit to our examiners for consideration to obtain CRA credit as a community development loan?