CD loan? Mod Inc jobs in Upper Tract

Posted By: ForceFull1

CD loan? Mod Inc jobs in Upper Tract - 03/29/19 07:48 PM

I'm new enough to intermediate-small CRA that I'm unsure of the answer here...
We originated a large loan to bring a new employer into our AA. A majority of the jobs coming are moderate income. The employer will be located in an upper-income tract, surrounded by upper- and middle-tracts. Can we count this loan as community development given the moderate income jobs?
Posted By: mrogersfib

Re: CD loan? Mod Inc jobs in Upper Tract - 04/18/19 06:57 PM

Yes, this would work as long as you had job statistics to support the statement that the loan will support LMI people. If a loan benefits LMI people or a geography then it is safe to proceed to the next step. Sometimes an activity benefits both LMI people and a Geography!