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#1092236 - 12/05/08 12:32 AM Community Development Credit
mzachau, CRCM Offline
Gold Star
mzachau, CRCM
Joined: Oct 2006
Posts: 470
San Francisco
Can we receive CRA credit for community development loans which are outside of the Bank's assessment area?

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#1092241 - 12/05/08 12:48 AM Re: Community Development Credit mzachau, CRCM
GuitarDude Offline
Power Poster
GuitarDude
Joined: Nov 2004
Posts: 5,925
So Cal
I believe so. I seem to remember that the regulator's stance is that you can get credit for CD loans outside your AA as long as you're satisfactorily making credit available within your AA.
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#1092256 - 12/05/08 02:15 AM Re: Community Development Credit GuitarDude
Mrs. Rizzo Offline
10K Club
Mrs. Rizzo
Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
Do the funds help your AA at all? What about a greater statewide effort?
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#1092840 - 12/05/08 07:55 PM Re: Community Development Credit Mrs. Rizzo
bubs63 Offline
Platinum Poster
bubs63
Joined: May 2003
Posts: 665
Highland Park IL
Depending on your regulator you may get get credit as GuitarDude stated. If you have convienced your regulator that you have addaquately supported CD in your AA you should get credit for all outside the AA also. You may also get credit for CDL if you can prove the beneifts to your AA. Example A CDL just outside the AA that will help with stabalizing or improving a tract, especially a LMI tract. I was told by a FED regulator that they are looking at the impact of CDLs on your AA. Prove that and you should be fine.
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#1095419 - 12/10/08 11:24 PM Re: Community Development Credit bubs63
Moman Offline
Platinum Poster
Joined: Jul 2004
Posts: 505
WA
Nada - our performance for CD loans was exemplary at our most recent exam. Our FDIC examiner looked at the "greater statewide or regional area" clause as meaning that if you were lacking CRA CD credit within the CRA Assessment Area, and had it in the "greater...area", then you could take it to give your CD performance a boost. In our case, we did not need it, nor were we given credit!

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#1095471 - 12/11/08 03:34 AM Re: Community Development Credit Moman
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,130
Connecticut
Most CD activity outside your AA won't count toward "satisfactory" performance, although it can contribute toward "outstanding" performance. The only exception that would count toward sastisfactory performance would be a loan or investment to or in an organization that serves an area greater than your AA but includes your AA. Even then, it is a good idea to restrict your contributions to such an organization to its activities specifically directed toward your AA.
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