If the bank donated money to this program, i.e., grants, then you are correct that this probably should have been addressed in the investment test. However, sometimes when we try to describe a particular program in a PE, the program may have features that fit more than one test. Rather than discuss the same program repetitively in the PE (and PEs in general are just too long), we may just discuss it once, putting it in the section that seems to fit the best. Without knowing the specific PE, perhaps that is what happened in your example. AR.