Has anyone ever successfully used a school's or a school district's Title I status to qualify a loan, service or investment as community development?

I have a loan to a school district that I really want to qualify as community development. The free/reduced lunch percentage of the district is just under 50% (47%). The loan is CAPEX for all district schools, so I can't just look at one school's free/reduced lunch status. None of the schools are in LMI census tracts. There are four schools in the district and two are above 50% free/reduced, and two are below, so I can't use that angle either. I've been to four different sources that provide free/reduced lunch percentage and have received similar results.

The only glimmer of hope I've found is that all four schools, and therefore the district, are designated as Title I. According to the U.S. Department of Education, Title I schools are designated as such based on the following:

" Title I, Part A (Title I) of the Elementary and Secondary Education Act, as amended (ESEA) provides financial assistance to local educational agencies (LEAs) and schools with high numbers or high percentages of children from low-income families to help ensure that all children meet challenging state academic standards. Federal funds are currently allocated through four statutory formulas that are based primarily on census poverty estimates and the cost of education in each state. "

Has anyone ever used Title I to qualify and had an examiner accept?

Thank you.

A school can be designated Title One for reasons such as lack of student performance, low attendance, low graduation or low promotion rates, etc., none of which have to do with the income of the students.

When qualifying a service, investment or loan to a school or school district, we always use the percent of students that are eligible for free or reduced price meals and not the school's designation as Title One. That has been the guidance presented to us by one set of examiners (FDIC).