Over $1mm infrastructure development loan for 54 lot residential development in designated distressed area...middle income census tract...any chance it might qualify for community development?

As you know the recently published Q&A tries to clarify what activities qualify for CD credit in the distessed and underserved tracts. What qualifies in distressed tracts may be different from what qualifies in underserved tracts. Based on the Q&A it appears that infrastructure improvements would qualify only in underserved tracts and not in distressed tracts. Activities that qualify in distressed tracts must "stabilize or revitalize" the tract. This has been interpreted to mean attracting or retaining businesses or individuals or the revitalization or stabilization activities are part of a bona fide plan to revitalize or stabilize a distressed geography. Some tracts are both distressed and underserved in which case infrastructure improvements might apply if your tract is classified as both. But remember that infrastructure improvements must meet essential community needs including those of low or moderate income people. Do the benefits of the infrastructure improvement meet the needs of low or moderate income people?

I guess the part that threw me was other bank activities in such areas generally wouldn't qualify UNLESS the area meets the distress criteria??? It's only a distressed tract, not underserved and the homes to be built upon completion of the infrastructure are not targeted towards low- to moderate-income individuals...