Community Center that rents to non-profits

We have a loan to a community center that owns a building with office and storage space. They provide office space and meeting rooms to non profits that serve LMI folks. Would this be CD? The loan is secured with a first lien on an endowment fund.
Thank you,

Is it in a LMI tract? Distressed county? Employ LMI individuals (reception/cleaning)?

It is in a middle tract, not distressed. If the answer to the Employ LMI Individuals, I might have something? Its not enough that it rents out office space to groups that serve the LMI folks? I suppose I would have to prove that the space is rented out at a minimum if that were the case as well.

I'd write it up either way. I was just trying to think of more "ammunition".

I don't think you'd have to prove the rent is at a minimum. If the tenant serves primarily LMI individuals, that should be ok.

Gather info on the non-profits that use the space for more ammo. Couldn't hurt

RR Jen - Maybe I misunderstood, but you saying that any borrower who owns a building and lets a non-profit that serves LMI individuals or families rent the space that CD lending credit should be considered, even if the non-profit is paying market rate?

I'm questioning the benefit to the non-profit serving LMI if they are paying market rate.

Can't hurt I suppose. I'll check the rent situation and also the surrounding census tracts. I FEEL like this should get us some points.

Tennismom: My logic could be flawed (and this one would take come creative writing skills since the non-profit is renting not the borrower) but isn't the non-profits mission to help LMI individuals no matter what they are paying for rent?

I've not dug out the Q&As but if the loan keeps the building available for the non-profit to help LMI individuals, do we HAVE to prove it's affordable to claim it as a Community Service CDL? The affordable part only comes in on housing, right? Similar to the size eligibility standards don't come into play unless you're trying to claim Economic Development.

If you've got something in the Q&A that mentions that, please let us know!

And where's Kathleen?

I was considering that the non-profit would have extra funds to apportion to the programing that serve LMI if rent was reduced or free.

I think that would be even more ammunition for a CDL, but not necessary. Hopefully Kathleen pops in soon, I'd be interested in her take.

Wow, so many great things to think about. While a pain in the you know where, CRA is kinda....fun???

It allows black and white compliance people a chance to get creative!