We have a request from a non-profit to refinance debt that they used to build homes for LMI individuals. The collateral for the loan is receivables. There is debate on whether or not this could be reportable as a CDL. The lender is arguing its a CDL because the original purpose benefited LMI individuals. Compliance is arguing its not a CDL because the refinance isn't benefitting any LMI individuals. Any insight is much appreciated!!

Why are they refinancing? If it is to get lower payments than one could argue that the funds saved would/could be used towards their programs that serve LMI individuals, i.e. - build additional homes.