There are 2 different median family income numbers that people constantly get confused by. As explained below, the first is used to determine the income level of tracts whereas the second is used for determining the income class of individuals. That's the number you should be using for determining if the renter is a LMI person.
From the Q&A's
§ __.12(m) Income level
§ __.12(m) – 1: Where do institutions find income level data for geographies and individuals?
A1. The median family income (MFI) levels for geographies, i.e., census tracts, are calculated using income data from the U.S. Census Bureau’s American Community Survey (ACS) and geographic definitions from the Office of Management and Budget (OMB), and are updated approximately every five years. Geographic income data, along with detailed information about the FFIEC’s calculation of geographic MFI data, are available on the FFIEC Web site at
http://www.ffiec.gov/cra.htm.The income levels for individuals are calculated annually by the FFIEC using geographic definitions from the OMB, income data from the ACS, and the Consumer Price Index from the Congressional Budget Office. Individual MFI data for metropolitan statistical areas (MSA) and statewide nonmetropolitan areas, along with detailed information about the FFIEC’s calculation of individual MFI data, are available on the FFIEC Web site at
http://www.ffiec.gov/cra.htm