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We have an opportunity with a local Habitat for Humanity to provide a Guidance Line of Credit for them to purchase properties to sell to LMI individuals. Seems to meet the definition of affordable housing for a community development loan. Has anyone encountered any problems with examiners counting these as CDLs?
A “community development loan” means a loan that:
(1) Has as its primary purpose community development; and
(2) Is not reportable as a home mortgage (HMDA loans), small business, small farm, or consumer loan, unless it is a multifamily dwelling loan.Your loan appears to have the appropriate purpose, but the line of credit appears to be a HMDA reportable loan and therefore would not qualify for CD credit unless the properties are multi-family properties.
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