Good morning!

I have $12MM loan to refinance a muti-family unit for LMI families located within our assessment area. However, the collateral used to secure the loan is located outside the Bank's assessment area and I cannot find anything within the FAQ's that indicates the collateral must be located in the Bank's assessment area to be considered for CRA.

Any guidance would be greatly appreciated.

Thank you!

It's based on the community being served. Collateral is usually relevant, but doesn't appear to be in this case.

Thank you!