for CRA purposes, does a bank have the option of using one of business or collateral address (assuming that they're not the same) if either is located in low-mod income community? Please advise.

Here is the rule we use at our bank. The main thing is to be consistant in your reporting.

If you are lending to a business to buy a piece of equipment that will be used permanently at a location other than the main business facility, you may use the address of the location of the collateral if you have it. Otherwise, use the business address. However, if the machinery is not in a permanent place, always use the address of the business.

In your reporting you should be consistent on which address is used for reporting. If you elect to use a corporate address always use that address.

If you use the business HQ address on some loans and address where the money went on others, then be prepared to explain why the inconsistency.

I believe there is a Q and A on this which I'll have to look up.