Would providing office space, on a permanent basis to the Hispanic Chamber of Commerce qualify as a CD Investment to the extent we can document the value? I've looked at the mission and vision statement. "helping businesses connect to the Hispanic community through education, networking and resources." I don't see anything about LMI. But, I'm asking.

Is there any benefit to small business as defined by CRA - running training classes there, etc.?

Not regularly. Their space will be one office. I doubt they could do much. I'll work on that angle. I think they provide networking opportunities with social hours, banquets, fund raisers.

If the Chamber is in a low or moderate tract, that can be used as another angle for CRA. They work with businesses to succeed, helping the area.

Very iffy txbr....if you can't verify small business or a program to support that has info verifying a benefit to LMI small business owners or entrepreneurs, the examiners will most likely throw this out for consideration.

I have had luck in prior CRA exams getting credit for programs targeting Hispanics because I used the census data to demonstrate that the Hispanics in our assessment area fell into LMI categories. You might be able to use the same logic that the Hispanic businesses are targeting the Hispanic population in your AAs.

txbkr - I think that the main question here is how are the Chamber members benefiting and not so much on the focus of targeting the Hispanic community. Remember that being Hispanic should not automatically be presumed as being LMI. I'm assuming that Chamber members are both non-Hispanic and Hispanic businesses. A few things to analyze. Are Chamber members located in LMI census tracts? Does the Chamber provide financial education courses to it's members? Has the Chamber attracted members to a certain census tract with the goal of revitalizing the area?

Luv.. Good questions.. I'll get a list and look at the business locations. Chamber does not provide anything except "networking opportunties" and a few small scholarships. They do not have any sort of revitalization goals that are shown in by-laws or mission statements. I ran this by an FDIC regional office specialist. Its a "no go", with the info I have at the moment.