I have a pretty decent size loan to purchase and renovate a multifamily apartment complex in a moderate income tract. The goal is not stated as targeting or structuring in a way to be "affordable housing", but is improving a pretty dumpy property. Rents will actually increase by about $50 per unit.

Revitalization credit? ISB.

I'd look at the rent roll on the pro-forma if available to see if the rents were affordable to LMI persons, based on median family income of the MSA or census tract if no MSA. I always have used the 28% standard for housing debt, and it has been acceptable to both FDIC and FRB for CRA purposes. Certainly would analyze and throw in the CRA bucket if at all possible, Cpl. Klinger!

If you can establish the project is consistent with a municipality's plans to revitalize or stabilize the area you would have a good case to substantiate the CD qualifications of the project.

Thank you both. Moman, do you have a source that speaks to the 28% standard?

This is a loan that was done, not looking to necessarily target "affordable housing". So, it's not discussed in the LP and I can promise you that wasn't the goal of the borrower when they undertook the project. I'm working backwards now trying to get credit after the fact. Not the best position, I know.

If a commercial construction-to-perm loan to build a multi-family/commercial space as part of a low CT revitalization project is outside a bank's assessment area, would you count it for community development? The project is in a state where the bank has a presence, but is not part of it's existing assessment area.

Appreciate feedback. Thank you!