I have a retail construction/development loan in a LMI area, one mile from a military base.

I was wondering if the loan would automatically be reportable because of its proximity to the military base.

Reportable as what??? It wouldn't be a small business loan because it is construction. Are you thinking Community Development?

It is reportable as a community development category of revitalization/stabilization. Thanks!

Careful are you referring to Revitalization and Stabilization of LMI areas in a in a designated Disaster Area OR a DESIGNATED distressed or UNDERSERVED non metropolitian middle income geography?

Stabiliation and Revitalization doesn't apply to all LMI census tracts just because they are LMI classified census tracts.

Careful are you referring to Revitalization and Stabilization of LMI areas in a designated Disaster Area OR a DESIGNATED distressed or UNDERSERVED non metropolitian middle income geography?

NO.

This loan is for the purpose of retail/construction development for commercial pad sites for restaurant chains (i.e. Chili's, Arby's, etc.) and a Walgreen's store. The area is surrounded by entry level homes, mobile homes, older apartments and very few businesses according to the officer. The census tract is moderate and there are few if none LMI positions/jobs outside of the military base.

So does this mean I can't get any consideration for revitalization and stabilization or it's too hard to qualify under this category? Even though this is close to a military base, does it provide any consideration/credit for CRA?

The military base part doesn't have anything to do with qualifying for CRA credit.

It doesn't sound like you have a designated disaster area or Middle income tracts DESIGNATED as underserved or distressed by the government so there is no revitalization or stabilazation.

If the loan is $1,000,000 or less, and not secured by residential property it may qualify as a CRA Small Business loan for which you can report and receive CRA credit.

From a CRA analysis standpoint you have made a loan in a low or modertae income census tract inside your assessment area which increases the percentage of loans in LMI tracts and inside the assessment area.

It wouldn't qualify as a small business loan because it is construction/development. It could however qualify as a community development loan. If it is for the revitalization of the area and will bring in jobs then it may qualify. I would run it by your regulator.

Thanks for your responses. This is kinda what I thought with taking the category of revitalization since it's creating jobs and it's a construction development of ($5.4MM). Just thought maybe the military base would give it extra support for CD, but it doesn't sound like it's doable. Thanks again...