CRA question

Have any of you had any experience with SBIC investments.

1. How large of a "regional area that includes your assessment area" have you been able to get away with?

2. Did you receive credit regardless of the size of the companies that received financing from the SBIC...companies with annual revenues of greater than $1million, some much greater.

Just curious what other's experiences have been.

I can answer number one. I've gotten credit for the entire state verses the 10 small areas I serve within the state.

In order to get the credit you need to demonstrate you did what you could within your AA, and then moved on outside of it. Alaska presents some very unique challenges when it comes to investments, not having the opportunity to take credit for Fannie Mae or Freddie Mac. This leaves me trying to meet the investment test with nothing but local housing bonds...which Fannie and Freddie buy 95% of (then they put them in a portfolio with so few AK deals in them I can't take the credit). So, if you're taking credit for deals outside of your AA, be sure you document why you need to do so very carefully.