We have a $44 million loan of for an apartment complex where only 20% of the units will be used as affordable housing. If we identify this loan as a community development loan on the CRA LR for the composite record the entire amount of the loan will be reported yet we really only get credit for $8.8M of it. Should we report a loan as community development where only a small portion is CD? We don’t have the ability to report only the $8.8M on the LR, it would be all or nothing.

When you say you don't have the ability to report only a portion of the loan on the LAR, can you not report totals in aggregate? We report (submit) the # and the $ of Community Development Loans, not individual loans.