Management feels there should be some CRA and/or Fair Lending credit or "goodwill" in the scenario below. I also feel the positive impact the deal will have on the community and tried my hardest to push this into the CRA box, but the lid won't shut

A for profit minority investor would like to purchase a moderate number of residential 1-4 family homes in an overall struggling urban center. This would end up being one commercial loan to finance the purchase, secured by the homes. The homes are located in some of the few upper and middle-income census tracts. Homes are currently being rented and after the investor purchases them they will be transitioned to owner-occupied homes.

What asset size is your bank?

How will the homes be "transitioned to owner occupied"? Will the buyers be low/mod income? Will the investor provide the financing or will your bank provide some home buyer credit training and potentially provide loans?