I came across a loan that I feel could qualify as CD, but not for sure how to document it. The loan was >$4MM and was to purchase and renovate a shopping center in an upper census tract. The businesses that moved into the shopping center consisted of restaurants, a furniture store, and a retailer of moderately priced family apparel. Overall, these businesses created 100+ new jobs.

Can I go after the "activities that promote economic development" because it supports permanent job creation? If so, how do I properly document my files to support this?

I beleive that you have to sell your bank's community development...If you think that it should be considered then it's up to you to defend your position and have a write up that proves your point.

Can I go after the "activities that promote economic development" because it supports permanent job creation?

The kicker on the reg is "These activities MUST also support permanent job creation, retention or improvement for PERSONS WHO ARE CURRENTLY LMI IN LMI GEOGRAPHIES, OR IN AREAS TARGETED FOR REDEVELOPMENT.

So unless you can show the 100+ new jobs were filled by LMI individuals in an LMI geography, IMO this loan will not qualify as Community Development.

We are now an ISB and I need to gain an understanding of community development loans. Any suggestions?