Hello - A local city government obtained a Section 108 loan from HUD, which the city will in turn lend the loan to a company for rehabilitation of an apartment complex that provides affordable housing. The bank I work at has been approached by this city government to serve as Custodian of various security documents, for which the bank may charge a fee. HUD requires this Custodian agreement. The bank would receive and store documents and would send them to HUD when received and also at any time they are requested.
We are a large bank. Has any other BOL user received CRA credit for this type of service? I think it may qualify for CRA credit under the Service Test, as a retail banking service, but I'm not so sure about that.
Any input would be appreciated.