We are researching financing a loan to purchase a shopping center. Loan amount over $1 million. The shopping center is located in a moderate income tract with other moderate income tracts surrounding it. The shopping center consist of grocery store with gas station, discount clothing store, discount dollar store, and a small sports store. Would this be community development loan and if so what do I need to document? Wages of employees employed at stores? Are employees residents of the tract or surrounding moderate income tracts?

Difficult to claim a CD purpose, just my opinion - it is an existing retail center, no new jobs, so not much you could argue for revitalize or economic development.....again, just my opinion.

That's what I thought. Thank you.

It's a stretch - but if loan proceeds were also used to renovate, repair or improve the shopping center, or if the loan made it possible for the property purchaser to retain tenants that might have left, you can make a case. But documentation to support that is as easy as trying to nail down jello.

There is a thought that occurs to me - Loans to purchase apartment buildings that provide affordable housing are almost a slam-dunk for Community Development. So why is it that loans to purchase shopping centers / strip malls, in Low/Mod areas also not given that kine of consideration?

Agreed!