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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All opinions are my own, not my employer's