Do community development loans have to be in your assessment area to get credit for CRA? We have a loan to a company located in our AA for an affordable housing complex being built just outside our AA. We generally report the address where the funds are to be used, so I would report the address that is outside our AA, and my CRA program isn't counting it in our CD totals. Can I just switch the address to the company address on this one loan?

That is strange that your CRA software is controlling what you do. I hate machines pushing me around.

You should report this loan. In the new proposed Q and As this type of situation ( is under consideration to count. Under present rules it could count under 2 scenarios:

1. your bank has met the needs in your AA
2. the project is adjacent to your AA and therefore will actually help individuals in your AA.

Do you submit a report annually? The report for CRA does not require geocoding for the submission, just total # and total $ of CD loans. If your list of loans is being controlled by your software, I would use the main address and then in my write up cover the actual location, etc.

Also, see if you can change that setting in the software.

Thanks KB! We don't report annually, but we have a CRA exam coming up early next year so we want to get all our ducks in a row before all the new regs come crashing down on us.