We've done the permanent financing for a housing development in a low-income area - however the units don't meet the lmi definition. Can we include this loan with our Community Development loans as the development is helping to "revitalize & stabilize" the area?

misha,

Is this a new development?

Is there something that you can point to that in fact does help stabilize the area?

If it is new, is this area part of a city or county designated redevelopment area?

It may be a long shot but if you can find some other reasons other than the fact it is in a low-income tract, you may as well mention it.

Documentation is key to getting credit; you have to prove your case.

I would argue that you are attracting new and permanent residents to the area.

If it's not multifamily and it is HMDA-reportable then you won't get CD lending credit (although you may get recognition for program that is "responsive to community needs"). If it is multifamily and it has a primary purpose of affordable housing or revitalization/stabilization of a LMI area then you are on your way to CD Heaven (assuming you have the proper documentation).

and you might want to be prepared to discuss how this is not contributing to the gentrification of the area....

Thanks so much everyone for the thoughts!

This isn't multi-family - it's condos. And it's not a new development - we've simply refinanced it. There are 5 residential units and 1 commercial space (think it's an attorney's office).

We were hoping to use the "bringing new permanent residents to the area" type of argument.

Just curious - anyone think we have a shot at our argument?

Without knowing all of the details, if the property was merely refinanced and the owners aren't doing something to the proeprty other than what they have been doing in previous years I don't see how it would bring new residents to the area.

Are the condos already occupied by the owners of the units?

If they are already occupied, as well as the commercial space I'm not sure how that argument will hold up.

Anyone else?

Also check to see if it is located in an enterprise zone or designated revitalization area.

IMO You will not get credit for this condo unit unless you can prove that is affordable housing. Which will be hard to prove. Kaybee as a good point if the building is in a enterprise zone you have a better shot and going for stablizing a low or mod tract.