I'm looking at a large agricultural loan (>$1mil operating LOC) to a farm located in a census tract that's on the distressed or underserved list. I'm trying to use it as a CD loan based on location, amount, stability/age of the farm, and number of people they employ. Am I way off base here?

Anyone?





Bueller?

I don't think you are off track, especially in a distressed/underserved area. I would stress use of funds and how it helps with continued employment etc in the area, contributes to the community (the farm has to purchase from other local businesses), etc.

And as with everything CRA (or any exam for that matter)

DOCUMENT!

DOCUMENT!

DOCUMENT!

And when you're sure you have it covered, document some more!

We get credit for exactly the same type of loan in a distressed area. So you are definitely on the right track!!

I have information on the community, the challenges the area faces and the number of employees at the farm.

Yep - Documentation! Document!

Examiners will not give you credit for a "say so."

Thanks, everyone. I had to lay this aside and get my HMDA submission finished, but am about to jump back in. Once I figure this one out I'll have my 2010 CRA reporting ready, too. It will be soooooo nice to be officially "done" with last year!