We have a loan over $1 million for the purchase of a franchise restaurant located in a low income tract. The borrower will continue to lease the property to the current owner. Can we report this as a CD Economic Development loan - finance small business/job retention - even if our borrower is not the owner of the restaurant but leasing it? We can get the number of employees that are considered low--moderate individuals based on the minimum wage jobs they employ.

Thanks,

Our regulator, the FRB, advised they would give CD Loan consideration to loans made to real estate holding companies. Our regulators said they will consider the result of the loan, not just the borrower.

What's more challenging is demonstrating the jobs were genuinely in jeopardy if not for this loan.