I haven't run across this before I'm thinking no, but let me tell you about it and see what others think.

There is an ACH guidance line of to the City of PoDunk. PoDunk is in a distressed middle-income census tract.

PoDunk will be using the the ACH credits for their payroll.

Being that this is in a 'distressed' tract should I submit it for community development?

Everything that I run across today is making my brain hurt.

If there were paying my OnUs checks would you submit it? The method of payment doesn't seem relevant to me.

it is a far stretch, but like AR always says, it can't hurt to try --

I don't know about the ACH part, but a guidance line of credit doesn't equate to an origination (as defined in our bank, at least). I would list it as an honorable mention in a self-assessment or whatever documentation you keep

I agree with Chris write it up and make sure you define how it meets the definition of CD

Could you show the ACH part as a service under the product part of service?

Yes you should as you would any accouont or service you offer to your customers.

Hmmm, a service? I never thought of that, great idea!

I'm not sure which way I will go with this yet, but I will definitely use it in one way or the other.

Thanks everyone!