The key to CRA when developing our lenders is to let them know that they have to be blind to all other factors besides income. Just because the morality of helping veterans feels as community development it is not so under CRA. What we have to look for is if the majority of their patience receive Medicaid if you want to go the community services route. Look to see if the hospital has a community assessment, and only focus on the financial nature of their clientele.
If you want to go the revitalization/stabilization route then you can take a few paths. First is finding out whether or not the loan will attract more residents to the area as I know that most veterans strongly prefer to use VA hospitals, and will travel or move to be closer to one. So are there a lot of low- to moderate-income tracts nearby, does the city have a redevelopment plan that mentions helping the clinic, or expanding the clinic. Another route you could venture down is that the loan will allow the VA Clinic to hire more employees.
§ll.12(t)—4: What are examples of qualified investments?
Facilities that promote community development by providing community services for low- and moderate-income individuals, such as youth programs, homeless centers, soup kitchens, health care facilities, battered women’s centers, and alcohol and drug recovery centers;...
§ll.12(g)—4: Can examples of community development activities discussed in a particular Q&A also apply to other types of community development activities not specifically discussed in that Q&A if they have a similar community development purpose?
A4. Yes.