Any guidance on how to best qualify a CRA activity based on federal poverty guidelines? Since the poverty guidelines are based on household size, are we using household size of 4 as a standard to compare to 80% AMI or are we trying to determine the average household size based on the geographic location?

Exactly what are you trying to do in this exercise? The primary beneficiaries for CD purposes must qualify as low- or moderate-income which is determined by dividing the beneficiary's annual income by the EMFI for the MSA or the statewide non-MSA in which they are located.