COMMUNITY DEVELOPMENT LOANS: ARE THEY HERE? ARE THEY THERE? COULD THEY BE ANYWHERE? STEFFANI JENKINS, CRA LIAISON, ICBA CRA SOLUTIONS ARE THEY UNDER A ROCK? ARE THEY IN A SOCK? COULD THEY BE AD HOC? CAPTURING COMMUNITY DEVELOPMENT LOANS CAN BE JUST AS EASY AS READING DR. SEUSS OR THEY CAN BE JUST AS HARD AS CAPTURING A MOOSE. OK, THAT’S A BAD RHYME BUT YOU GET THE IDEA! THE KEY IS KNOWING WHAT A COMMUNITY DEVELOPMENT LOAN IS, HOW TO FIND THEM, WHO REPORTS THEM, AND WHY THEY ARE REPORTED. What is a Community Development Loan (“CD Loan”)? The primary purpose of a CD Loan must be for affordable housing, revitalization, and stabilization of a LMI area or to promote economic development/create jobs for low-to-moderate-income people. A CD loan cannot already be reported as a small business or small farm loan. It also cannot already be reported as a HMDA loan, unless the loan is for the purpose of multi-family affordable housing. This is the only instance when the loan can be reported under both HMDA and as a CD loan. If CRA qualification is based on job creation, gross annual revenue size eligibility requirements must be met based on the Small Business Administration’s guidelines found here: https://www.sba.gov/document/ support-table-size-standards. Under the current CRA rule, the loan must also benefit your bank’s assessment area or a broader, statewide or regional area that includes the bank’s assessment area to qualify for CRA credit. 10 feature
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