My credit administrator thinks a commercial loan to a business owned by a tribal member is community development. It would still need to benefit LMI, right? It's definitely a minority-owned business, but that may be where it ends....

Under which exam methodology and regulator are you examined?

Large bank, FDIC.

If the loan is less than $1 million, it would qualify under small loans to businesses and farms. For a larger loan, you would need a community development purpose, but if the business is on tribal lands or in an LMI geography, loans that support continued or expanded employment could qualify as promoting economic development or revitalizing/stabilizing LMI geographies (assuming the geography is LMI).

Community development also includes tribal-based childcare, healthcare, education, social services, and workforce development/job training programs targeted to low- or moderate-income persons.