Posted By: Nicole H.
HMDA Repurchase of Multi-family Affordable-CD Qual - 03/27/19 04:15 PM
We originated a loan in 2010 to a Housing Authority for the construction of a multi-family affordable apartment complex for seniors. This was also a LIHTC deal. We sold this loan to the Housing Authority in 2013. The Housing Authority has now asked our bank to repurchase this loan to free up money for them to use for other projects. This loan was reported as a community development loan (as well as HMDA) in 2010. Is the repurchase eligible to be reported as community development again in 2019? I'm unable to find any information regarding this scenario from the CRA perspective.