RE: # 1 – The economic development qualifying must meet both the “size” and “purpose” test. Per the Q and As, https://www.govinfo.gov/content/pkg/FR-2016-07-25/pdf/2016-16693.pdf
To meet the purpose test it should: support permanent job creation, retention, and/or improvement for persons who are currently LMI or support permanent job creation, retention and improvement in either LMI geographies or in areas targeted for redevelopment by Federal, State or tribal governments. In addition any investment in or loan to a SBDC, SBIC, Rural Business Investment Company, New Market Venture Capital Company or New Markets Tax Credit-eligible Community Development Entity.
RE: #2 – We use the Fair Market Rent Documentation System https://www.huduser.gov/portal/datasets/fmr.html
to determine if rent is affordable. If the rent charged is above the rate(s) listed we do not consider it affordable housing. Also, it has been suggested that even if a property’s rent is within the fair-market rent range, we need to evidence that low-and-moderate-income individuals and/or families are actually benefiting – not middle-or upper-income individuals or families paying at or below market rate rent.