Came across something "new" and wanted to see if anybody had thoughts on this that might be helpful or if anybody had experienced this before.

Apparently, there are a few Census Tracts across the country that do not have a status as far as "Low, Moderate, Middle, Upper." They are instead given an "Unknown Income" categorization. If a Bank is determing whether or not a particular loan meets the defintion of a CD loan under CRA, how should they treat such a situation? Use the underlying information (such as nearby CTs, Poverty Level, Median Salary from last time it was published, etc.) to make your own determination to conclude whether the Tract is likely L or M?

I have often referred to other demographic systems like HUD to see if the area qualifies. If you are trying to qualify the loan based on Geography vs LMI people then any government system that uses widely available data would be enough to suffice. In these instances though I would look to qualify the loan based off of the people benefiting from the loan vs the demographics benefiting since it's much less time consuming.

Thank you for giving it a shot