Other than the Section 8 apartments do you know anything about the income of the other occupants?
There are several ways you could get CD credit under affordable housing. You need to know if the rents are affordable for tenants at or below the moderate-income level and you need to know how many tenants are qualified as LMI persons or families.
Then you must pass the "primary purpose" test which can be done in 1 of 3 ways, (1) the majority of rents are affordable and enjoyed by LMI tenants, (2) written documentation from the property owner regarding the purpose of affordable housing and LMI tenants (need not be >50% using this method) and the deal is structured to fulfill that goal (set aside provision for example) or (3) documentation showing less than 50% of tenants are LMI and benefit from affordable rent - you can get pro rata credit under this last method, whereas the first 2 you can report 100% of proceeds as qualified.
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