Do I understand correctly that if we make a loan or investment in one of these designated disaster areas that meets the CD definition, we WILL get CD credit for it, even if it is outside of our AA and state? Is this for only ISB or can large bank do it to?

If the hurricane area is not part of your assessment area or a larger area of which your aa is a part, you will not get credit for the activity if you are not already meeting the community development needs of your area. If you are already satisfactorily meeting the CD needs of your community you will get added consideration for your hurrican area activity. This is a very important condition for you to get CD credit. Too many bankers may look at the revised regulation and Q&A's and conclude that they will get CD credit as part of their obligation to meet the CD needs of their community, but this is a big mistake.

That is the tricky part, huh? How do you prove that CD needs are being met in your AA when there are so few opportunities? Lack of opportunity is why we are considering the hurricane area. There is always a need for LMI housing. In the scheme of the overall market, we are a pretty small player and the big boys have not taken the lead. We don't have the resources to start a housing project on our own and no one else has either. CD opportunities are hard to come by, thus we retain our option to be evaluated as a large bank as the discussion goes in the other thread..