I am in the process (along with everyone else) of scrubbing my CRA & HMDA data before submission. I have 5 loans that were refinanced last year. These are refinancings of multi-unit apartment buildings that were specifically designated for LMI individuals (done through a partnership with the WI Economic Development Authority). The renters need to be under a specified income to live there (I have documentation of this).

I know that in addition to reporting these as refinances under HMDA, I should be able to report them under CRA as a CD loan regardless of the loan amount.

#1 Is this correct? Can I report these as CDL's under CRA even though the amounts are under $1 million?

#2 These properties are not in my assessment area (they are in Wisconsin. I am in Minnesota). However my customer who purchased the buildings is. Upon further review, I don't think I can count these because the properties are not benefiting my assessment area or a larger area that includes my assessment area. Is this correct?

Any feedback asap would be awesome...I'm trying to get this file out of here today!!!

Thanks!

1. Yes - you can report "CD qualifed" multi-family secured loans that are under $1 million as community development loans even if they are HMDA reportable.

2. Correct - You can't count these loans as community development loans because they are not benefiting your assessment area or a broader area that includes your assessment area.

No no no no, let me disagree with number 2. I report deals way the heck out of my assessment area as CD loans. It's qa "broader statewide or REGIONAL" area. So, before you count these out, how close are they to your assessment area? Was anyone else providing this type of financing in the area? How necessary was the housing?

I take credit for deals hundreds of miles from my assessment areas because I'm the only bank that ponied up to do the necessary work in the community. The deals had benefit that was easily qualified and I serve my assessment area, so stepping up to the plate to serve another need isn't a stretch. I receive full credit for them without question.

So, how far are they from your area? I know the two states are very closely linked. (Heck I had dinner in Wisconsin when I was in the twin cities). Remember the line is a broader statewide or regional area. Fit it in that "regional" area and explain it. Can you make it work now?