[neldajapan]

Good Afternoon Jack:
Our bank has several loans given to individuals or corporations that are secured by notes receivable. These individuals or corporations borrow money from the bank to buy homes, which are then sold to “LMI individuals”.

Can these loans be given CRA credit consideration since the funds are indirectly being used to house low-to-moderate income individuals? My colleague is suggesting that I follow the money one step further from our customer.

Help 🙂

[neldajapan]

Thank you for your response. I have one additional question, please.

With reference to SBA PPP Loans: Are we required to use the payroll cost information found on the PPP loan forgiveness application in order to determine CRA credit eligibility? Would you please provide me with the supporting documents required to qualify a CRA eligible PPP loan. Currently, we documented and qualified these loans if they met the criteria regarding industry size standard data (NAICS) and industry wages found on BLS.gov. Is this process lacking payroll data for CRA eligibility, which was obtained at loan forgiveness time?

Below are the supporting documents currently attached to each loan:
BLS Wage Industry Data
2021 Income limits
Borrower PPP Application
NAICS Data
Company website profile (About page)

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