This may be a strectch, but I'm wondering if this loan might qualify as a community development loan. The loan is for $2.5 million to construct a new hospice center. It's creating six new jobs (I can't prove that they're for low/mod income people). I have a policy in hand that discusses their program that provides home care services to those who do not have adequate insurance and cannot otherwise afford home care. What do you think?

What qualifies for community development under CRA?
1 - Affordable housing for LMI persons
2 - Community Services primarily for low or moderate-income people
3 - Economic development by financing small businesses
4 - Revitalizing or stabilizing low or moderate income tracts or distressed and underserved geographies

Does your loan accomplish any of the foregoing? If it does, it would seem that somehow it would have to be under #3 if certain conditions applied. But it does appear to be a stretch.