We have a loan to purchase a 6-unit retail building. The property is located in a moderate income tract. The area is in an Enterprise Zone but the subject property is not. One side of the street address is but the other side is not. We are unable to obtain any information from the tenants regarding the job positions/salaries or the number of employees.

Can we still consider it a CD loan based on -

- the subject property is in close proximity to an Enterprise Zone
- getting the average wage from the BLS based on the type of business to document job retention for LMI

What other documentation would we need? Or should we not even consider it.

Thank You.

If the apartments are designated for low income individuals or if the rents are below HUD's fair market rents, you may be able to qualify the loan under affordable housing.

HUD Fair Market Rent Website

Since you are talking about a moderate income tract I would try to meet some of the factors related to revitalization/stabilization. I would document the enterprise zone information, for example is there anything within the enterprise zone designation that might tie to economic development or revitalization? Is there anything about job creation/retention that would involve LMI individuals?