:raises hand:
That might have been my link. We got some miles out of that designation. We did not document the specific LMI need for healthcare. We were able to convince our exam team that LMI individuals benefit from any healthcare availability in the community. Granted our exam team is fairly flexible.
And THAT is one of the problems with CRA these days. We were denied CD credit for a renewal of a participation loan that had received CD credit in our prior exam - and loan was to a major health care company that purchases hospitals in danger of financial collapse, re-organizes the management of the hospital to keep it open. There were two hospitals in LMI areas in our AA included in the portfolio. Examiners said we couldn't prove a "majority" of benefit to LMI and FURTHER told us that "hospitals are not community services" that qualify for CD.
Yeah - we protested all the way up the chain. Didn't matter.