I'm frequently asked to determine if a loan could potentially qualify as community development while it is in the application stage. When I opine in these situations, I always tell the lender that the determination is subject to change upon full review of the closed loan file.
Now I'm seeing loans that have recently closed, but that began pre-July and before the FFIEC updated the demographics that vastly changed census tract income levels. These loans were previously of benefit to low- or moderate-income areas, but now are not. What to do? Obviously, if there was more than one qualifying factor on the loan, I go with that (and note that the tract was previously low/mod in the write up). But I hate to lose those community development loans in tracts that were previously low/moderate but now are middle/upper, and especially those loans where lender or other staff worked diligently to find and originate in a low/mod tract, but now will not qualify.
What are you doing? Have any of you been through a recent exam experience this year dealing with this? Are examiners willing to give credit in these situations? Thank you.
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Six consecutive "Outstanding" Large Bank CRA Ratings.... and counting.