Opinion please:

# 1 - Loan to non-profit church for working capital to support membership growth and improve facilities?

#2 - Loan to non-profit Homeowners Association for siding and roof replacement/improvement?

Thanks in advance

Just the mere fact that the company is a non-profit does not qualify this as CD. There must be some link to LMI individuals or LMI census tracts. For example, the church I attend is a non-profit organization, but is not focused on LMI and is located in a middle-income census tract. A working capital loan to my church to support membership growth and improve facilities would in no way be considered a community development loan.

And...adding to Jim's answer...

If the proceeds are to be used strictly for the church benefit, and not the general benefit of all members of the community it is not CD worthy. If a project is eligible for CD Credit it must serve any members of the community, not the ones who believe in God through that particular congregation etc.

The second loan could be possible..if the non-profit Homeowners Association serves low or moderate-income residents. My Homeowners Association is a non-profit, but the residents are not low or mod. Even a high income condo association will be non-profit. Dig a little deeper and see who really lives in the units.

Well, this may be where Dawnie and I disagree a little. If you made a loan to a church located in an LMI tract, with a congregation made up of significant portions of LMI individuals, and the loan was to provide a day care facility at the church for the LMI church members to use, I think you could get CD credit for that loan even though it doesn't benefit the whole community. It's no different than a CD service to an LMI school - there is no benefit to the entire community there - just to the ones that attend that school.