Keep in mind that if the loan is reportable as a small business loan it cannot be double counted as a CD loan. You don't give enough info to know if the loan is $1 million or less. Moreover, it would really be helpful if the loan was consistent with a bona fide government plan for revitalizing the area. Has the state or local government developed a revitalization plan and if so would your loan fit within the plan? These things can only help you defend your position if it is challenged by examiners.
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