In April 2012 FRB put out a statement regarding CRA credit for OREO residential property. Is the FRB allowing CRA credit for the sale and bank financing of a small business commercial OREO?
I think the point of the credit for residential property was to help stabilize NSP areas that were hit hard by residential foreclosures. Someone please correct me if they know otherwise.
The loan qualifies as a Small Business Loan (01E) but since it is our OREO and we financed the purchase not sure if it can be counted as a new CRA loan. Anyone have an opinion?