CRA CD Investment

Posted By: Norman Paperman

CRA CD Investment - 02/01/19 05:45 PM

$30MM State Revenue Bond to fund the construction of a historical music/culture museum located in a middle income tract downtown. The tract is surrounded by at least five moderate income tracts.

Any case to be made for revitalization/stabilization of the area? The entire downtown district is experiencing a revitalization period.
Posted By: mrogersfib

Re: CRA CD Investment - 02/05/19 10:13 PM

Are there any Federal, state, local, or tribe revitalization/stabilization rehabilitation plans in place that support the project? Can you look at the state bill that passed to see if there was language or stipulations that required the funds to be used in a way that rises to CD?
Posted By: Lori01

Re: CRA CD Investment - 02/14/19 06:12 PM

What about the jobs it creates....someone will have to work there. Will those jobs be for LMI wages?
Posted By: Norman Paperman

Re: CRA CD Investment - 02/21/19 09:09 PM

Nothing on the MrRogers front. Thanks for the suggestion.

Lori, I can't make even a marginally strong case for job creation, there is zero info on that front.

Thank you both.
Posted By: mrogersfib

Re: CRA CD Investment - 02/21/19 10:30 PM

Might argue that this is essential community facility for the area and it helps raise property prices, attract businesses, and residents to the area. USDA defines an essential community facility as: "An essential community facility is defined as a facility that provides an essential service to the local community for the orderly development of the community in a primarily rural area, and does not include private, commercial or business undertakings."


§ll.12(t)—2: Are mortgage-backed securities or municipal bonds ‘‘qualified investments’’?
As a general rule, mortgage backed securities and municipal bonds are not qualified investments because they do not have as their primary purpose community development, as defined in the CRA regulations. Nonetheless, mortgage-backed securities or municipal bonds designed primarily to finance community development generally are qualified investments. Municipal bonds or other securities with a primary purpose of community development need not be housing related. For example, a bond to fund a community facility or park or to provide sewage services as part of a plan to redevelop a low-income neighborhood is a qualified investment. Certain municipal bonds in underserved nonmetropolitan middle-income geographies may also be qualified investments.