Has anyone ever been able to get CD credit for a construction loan to remodel a public library in a middle-income tract?
I have a library that is about to undergo major renovations, including adding space and most importantly bringing everything up to code for ADA. Right now most of the entire building cannot be accessed by anyone with mobility issues. They will be adding a lift and making other changes to correct this. Since a library doesn't ask for income information from their clients, and this one is located in a middle-income tract, I don't see a way to get CD credit, but perhaps someone has been in the same situation and was able to come up with a creative way to have examiners agree this is really a CD activity? (large bank, FDIC)
I have not but a thought would be to access the disability information (I think under the Health category) from the US Census website for the area that library serves. It should give you a percentage of how many are disable. I am sure the goal is for the library to upgrade their facilities to attract more disabled patrons. It could help to get an income range for disability income in your area to show their income would be under the median income.
#2284045 - 05/02/2305:32 PMRe: Construction loan to a library Lori01
Inherent_Risk
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Joined: Jan 2017
Posts: 642
I would certainly try. Go to the library's website. See what they do. Most public libraries have a plethora of features and programs to serve lmi populations.
We always highlight the free to use internet at public libraries, and note that LMI individuals may use that internet to apply for jobs, government benefits, etc.
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