I am trying to find more CDLs before I submit our HMDA/CRA data. I am hoping to include some multi-unit dwellings located in low- to moderate-income census tracts that will primarily have LMI renters. I thought that I read somewhere that the rental charge had to be below a certain area threshold to count as a CDL. The problem is that the owners of these units are not "focusing" on renting to LMI persons. However, I am hoping that the rents being charged on some of these units might be low enough to count as a CDL; however, that would be by pure luck and not design for LMI persons. I also don't know how I would prove the occupants of these properties are LMI, besides showing the rents are low and the property is located in an LMI census tract. Is that likely enough for an examiner and where would I find this magical "area rental charge threshold," if it even exists (I might have imagined reading about it in all of my confusion in 2004)? Basically, would I be wasting my time researching these deals hoping that the rents are low enough to be considered for CDL purposes? Thanks for the help.

Do a google search for HUD Fair Market Rents, include your area (county, city, state, whatever) as well as the year of the loan you are reviewing. The fair market rents is the target you're shooting to be below for inclusion in your CD file.

You don't need to "prove" that the units are inhabited by LMI people. You do need to show that there is a likelyhood that they are, based on population base (geographic tract income levels) as well as any external factors that would lead you to believe this (ie close to a base). Then you use the fair market rents as your guide and show your rents are below those, thus making it affordable. If you're having trouble finding rent rolls, look to the appraisal. It will have rents listed on....probably page 2 or so. Look to actual rents, not suggested market rents.

Be sure to look to purpose of the loan. If the CD deal is affordable rent, it still won't count if the actual purpose won't benefit the market. (IE a land baron taking funds out to remodel his castle)

Thanks Dawnie, you're the best.

I found the 2004 HUD FRMs, my only question is why HUD has not updated my state's MSAs? The data I have clearly states "Fair Market Rents 2004 for existing housing," I have to question the data though because the old MSAs (2003) are listed next to the data sets. I looked at the 2005 FRMs and they also have the old MSAs listed. Does anyone else have these same issues?

That is a question for Don...DONNNNNN (I'm pm him and ask if he can help) My answer would be something in the nature of....what do you expect from DUH...I mean HUD