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#2088422 - 07/15/16 09:34 PM CD loan in Upper Income Tract?
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 1,984
Idaho
We did a 4 million dollar loan that was for the purposes of completely rehabbing a large commercial facility, similar to a strip mall. The building has fallen into disrepair and was foreclosed on (not by us). The building currently has one tenant that occupies 50% of the space. The building is in an upper income tract. The building is located near a lake, which is the only reason why the area is upper income (large homes on the lake). There are several moderate income tracts that surround the upper tract.

The rehab of this facility will definitely create jobs and since it is a retail facility, those jobs will likely be lower income. I'm hesitant to try to claim this for CD credit due to the fact that it is located in an upper income tract, but it seems like it might meet the economic development test.

Thoughts?
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CRA
#2088426 - 07/15/16 10:06 PM Re: CD loan in Upper Income Tract? TMatt87
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
I would focus on the jobs creation, being very specific (types of tenants in property, etc.) and the distance to moderate income tracts. If travel to the site is reasonable (I do not know size of tract), and commuting is the norm you likely could get credit. The wealthy people with lake homes likely won't want the jobs.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
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#2088509 - 07/18/16 02:34 PM Re: CD loan in Upper Income Tract? TMatt87
Pale Rider Offline
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Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
^^^ that! Economic development with low skill low wage job creation.
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Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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