Episode 66: CRA Tips: Revisiting the Fundamentals: The Most Overlooked CD Hook
In this episode, we’re taking a deeper dive into the economic development hook, which is often an overlooked aspect of community development loans. However, it plays a crucial role in strengthening local economies. Here, you’ll learn how to identify community development loans that were originated for small businesses to support your community development loan portfolio.
Remember, when qualifying for a CD loan under the economic development hook, you’ll need to meet the size and purpose test. The criteria to meet the test are:
- The borrower must be considered a bona fide small business per Small Business Association (SBA) standards. You can view their standards here: U.S. Small Business Administration Table of Small Business Size Standards
- The borrower or purpose of the loan must also retain or create jobs for low or moderate-income individuals
Credit write ups don’t usually include salaries or job information, CRA professionals will have to make a few reasonable assumptions and document their approach for an examiner’s review. The interagency Q&A has guidelines to help frame your approach. This episode includes some examples of common small businesses that qualify under the economic development hook.You can reference the Bureau of Labor Statistics to document information on representative jobs and income levels based on the loan originated and its local demographics and economic statistics.
- CRA Today Website: https://cratoday.com/
- CRA Hub: For more Community Reinvestment Act training resources, check out the Hub! https://cratoday.com/hub
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Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/
Copyright © 2023 by CRA Today LLC
(No claim to original U.S. government material)
(No claim to original U.S. government material)
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This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.
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