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#2209914 - 03/29/19 07:48 PM CD loan? Mod Inc jobs in Upper Tract
ForceFull1 Offline
100 Club
Joined: Nov 2003
Posts: 245
smalltown Iowa
I'm new enough to intermediate-small CRA that I'm unsure of the answer here...
We originated a large loan to bring a new employer into our AA. A majority of the jobs coming are moderate income. The employer will be located in an upper-income tract, surrounded by upper- and middle-tracts. Can we count this loan as community development given the moderate income jobs?

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#2211549 - 04/18/19 06:57 PM Re: CD loan? Mod Inc jobs in Upper Tract ForceFull1
mrogersfib Offline
100 Club
Joined: Aug 2018
Posts: 116
Yes, this would work as long as you had job statistics to support the statement that the loan will support LMI people. If a loan benefits LMI people or a geography then it is safe to proceed to the next step. Sometimes an activity benefits both LMI people and a Geography!

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