Two quick questions: CRA rules state that qualifying community development loans for low-income housing include multi-family loans for low- to moderate-income individuals that benefits the Bank's assessment areas (or) a broader statewide or regional area that includes the Banks's assessment area. I am brand new to CRA and would like to bounce a specific situation off of you CRA experts. We are considering a Section 42 low-income housing project that is located in a county that is literally "across the river" from one of our identified assessment areas and "across a highway" from another assessment area (picture the letter "L", and the project would be literally where the two lines meet). It is my opinion we would get credit for this project. Any thoughts?

Second question, we already have done Section 42 low-income housing project in a county that is three counties (or about 120 miles north of our large metropolitan MSA). In your opinion, would this qualify under the "benefiting a broader statewide or regional area"?

Any input would be greatly appreciated. Thank you.

IMO you would get CD credit, just have a good story on why you are making them outside your AA.

As long as you are doing Community Development Loans in your assessment area, you will get credit for what you do on a regional or state wide area, IMO. If you do not then they may not allow CD loans you made out of your AA.

It sounds like the first 2 situations would qualify. But the last loan is much more difficult because of its remoteness to not only your assessment area, but to the MSA in which you are located. If it is 120 miles north of the MSA, how much father is it from your Assessment Area? If you haven't done any CD lending in your community it is less likely to get credit. However, if you already have done a satisfactory job of meeting the community development needs of your market, then it would be icing on the cake. The priority is to take care of the needs of your market first.