I am trying to find a way to make a loan we did qualify for CRA credit. We are an ISB.
The loan is in a county with only middle income tracts. There are 3 employees but they aren't considered low or moderate income level.
The loan is to a water and sewer company.
Is there another angle I can go about to make this qualify?

Private or public company?

Private

Only thing you can do at this point is look for a disaster in the area in the last 36 months of the loan that you could say this loan helps build up critical infrastructure in a disaster zone.

Are the middle-income census tracts in a non-metro area that is designated as being "underserved"? Providing essential infrastructure such as water and sewer could qualify in this regard as the water service would include meeting the needs of LMI residents.