We are reviewing a potential new community development loan for the Bank for a water sewer district loan request in a MODERATE income census tract area for a local county governmental office. The area is surrounded by 4 moderate income areas, 3 middle income and 1 upper income census tracts).

Loan proceeds are targeted for the refunding the district's outstanding state revolving loan fund and to pay off the issue. Original loan proceeds, now being refinanced, were of a water & sewer system, sewer collection and transmission, treatment and disposal facilities.

Because it is serving a moderate income community and providing funds for the outstanding loans, we are leaning towards counting this loan. Any issues?

If the water district serves all, or more than one of the census tracts, you may have to settle for only a portion of the loan being CD.

Id write the whole thing up, focus heavily on your moderate income areas, and see what the individual examiner says.