Community Development dentist or eye doctor

Posted By: Live 2 Comply

Community Development dentist or eye doctor - 05/22/18 08:31 PM

Could financing for an eye clinic or a dentist office be counted as a community development loan for CRA?
Posted By: ScoutLaRue

Re: Community Development dentist or eye doctor - 05/23/18 02:30 PM

Do they accept patients with low to moderate income, no insurance, Medicaid, do some sort of payment plan--- and keep records of it?
Is it in or very close to an LMI tract?
Is it a brand new business that will bring new jobs to the community that pay LMI wages? Office staff etc?
Posted By: Norman Paperman

Re: Community Development dentist or eye doctor - 05/23/18 02:46 PM

Is the area designated as a Health Professional Shortage Area?

https://datawarehouse.hrsa.gov/topics/shortageareas.aspx
Posted By: RR Jen

Re: Community Development dentist or eye doctor - 05/23/18 03:10 PM

Holy cow, thanks for sharing that link. Searching by addresses (a few clicks away) is cool!
Posted By: Live 2 Comply

Re: Community Development dentist or eye doctor - 05/23/18 07:42 PM

Thanks for everyone's help! Very beneficial!!
Posted By: Andy_Z

Re: Community Development dentist or eye doctor - 05/23/18 08:15 PM

Norm - I was not aware. Great link. I'm sure Scout's questions, answered affirmatively would add credibility, but how much credit could a lender get if the office located there, but couldn't document LMI needs?
Posted By: Norman Paperman

Re: Community Development dentist or eye doctor - 05/25/18 02:09 PM

To be honest, I have my first CRA exam coming up using this method. I hate to say that I can't remember the BOLer that shared this with me, but no surprise that I learned of the link from a fellow user.

I think it can hold weight.
Posted By: CompliantOkie

Re: Community Development dentist or eye doctor - 05/25/18 04:02 PM

: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.
Posted By: Princess Romeo

Re: Community Development dentist or eye doctor - 05/25/18 05:16 PM

Originally Posted By CompliantOkie
: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.