We relocated a branch. Based on the distance between both branches it was considered a relocation and not "closed." The question is, that if we must include that relocated branch in our CRA Public File as a closed branch?
When reporting revenue on the small business LAR can you please clarify the following for me:
We have a loan program called "Low Doc" in which financials are not used in making the credit decision based on a number of factors, however we do have the revenue information from the customer. In order that these loans are not reported as a code 3 – and not counted in our CRA totals, is it appropriate in using the business revenues that the customer provided?
What documentation would you suggest to prove a community development loan with the purpose of revitalization/stabilization in a moderate- income area? We are financing the purchase and construction of a mixed use development with upper income housing, retail and commercial space. The housing units have been completed but our loan will finance the finish out of the retail/commercial space. Development has TIF credits that our borrower will receive.