I found an LOC in our portfolio to a residential contractor that is building spec homes in a moderate census tract. The homes are being sold at market value, so there's really no way this loan qualifies as community development, correct?? Trying super hard to find CD loans.….

It's a good sign that the subdivision is located in a moderate-income census tract. But, you have to prove that LMI people will benefit. So in the instance of affordable housing--are the homes being sold under the median home sales price in the area? If a portion are being sold you could take the pro rata share of the loan. In the instance of revitalization/stabilization does the loan attract LMI people to the area or substantially improve the area for the LMI tract? Are there any Federal, state, local or tribal revitalization or stabilization plans that are consistent with the loan? Has the area been designated as a disaster area in the last 3 years?

Thanks for your feedback, mrogersfib.

Another scenario.....original loan was an SBA 504 over $1 million, so it qualified as a CD loan a few years ago. In 2018, we renewed the first lien, which is over $1 million. Can I count this renewal as a CD loan under economic development in 2018?

You could using the original documentation showing that the loan was part of a SBA 504 previously, and substantiate that with any Federal, state, local or tribal economic development plans in the area. I think the examiners will just assume it qualifies as it is part of a 504. As long as there is an increase or an extension of maturity you have an "origination" under CRA/Call Reporting.