I am working with my business lenders to review their originated and renewed loans in 2011 for CD credit. We found 2 loans to a company that leases facilities to CBRFs. The CBRFs receive government assistance to pay housing cost for the residents. I am trying to figure out, do these qualifiy for CD credit? At this point my feeling is no, because the loans are not directly to the CBRFs. The company that owns the facilities could lease to any type of business and does not have any CD purpose it self. Any thoughts would be helpful.

I would dig deeper into the purpose of the loan. If it was to perhaps modify the facility to make it meet CBRF requirements, you might just make the case.

Thanks for the advice, I will see what I can dig up.