would a well capitalized financial institution be eligible to apply for the ECIP investment? We do not have most of our loans in low or moderate income areas and no in rural.

To me this is applicable more to those banks that are located and majority of their loans are located in low-moderate income areas and rural.

Thanks for your guidance.

Well, to begin with, the financial institution must be a certified Community Development Financial Institutions (CDFIs) or minority depository institutions (MDIs). Start there......

We are an MDI.

I'm not clear as to the following scenarios if they apply or not.

Loans to recapture equity? I say No,

When identifying if a borrower is a minority, since most are business type loans and we do not collect that data should we go by the census data the provides the % of minority in the census tract? If so, should we use the census of the property or business that secured the loan or should it be the census tract of where the owners of the business is located?.

I am also curious how other CDFIs applying for this investment will gather demographic data on their customers. Management is requesting that we find a way to reflect the information on deposit customers, which we have never done. Has anyone else found a way to accomplish this in a compliant manner?