Ideas of how an examiner will look at this gets quite esoteric when comparing rents and what is below market. I doubt they will take an appraiser's word for it, although they may be considered a third party to the bank. Any idea what rent the appraiser was using for market rent? When he established the market rent, did he then take 80% of that number to determine the rent for low-and-moderate-income individuals to determine affordability?
But don't give up, since it is an LMI tract, maybe you can argue stabilization rather than affordable housing.
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