We have some construction loans to a housing fellowship organized as a non-profit organization to construct spec homes to be sold to LMIdividuals. Since these are not reported elsewhere on the HMDA LAR can we report them as community development loans? Thanks for your help!

Are they reported anywhere on your CRA LR? (It sounds like they shouldn't be, but just in case I want to ask).

Sounds like an easy CD deal to me, if you can document the focus of the entity on LMI buyers (should be in their business plan).

You say "not reported elsewhere on the HMDA LAR". Are they "anywhere" on the HMDA LAR at this point? The terminology is throwing me off a bit