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Must a community development activity occur inside a low-or moderate-income area, designated disaster area, or underserved or distressed nonmetropolitan middle-income are in order for an institution to receive CRA consideration for the activity?
No. Community Development includes activities, regardless of their location, that provide affordable housing for, or community services targeted to, low or moderate-income individuals and activities that promote economic development by financing small businesses and farms.
Activities that stabilize or revitalize particular low- or moderate-income areas, designated disaster areas, or underserved or distressed nonmetropolitan middle-income areas (including by creating, retaining, or improving jobs for low- or moderate-income persons) also qualify as community development, even if the activities are not located in these areas.
One example is financing a supermarket that serves as an anchor store in a small strip mall located at the edge of a middle-income area, if the mall stabilizes the adjacent low-income community by providing needed shopping services that are not otherwise available in the low-income community.
Reference: FDIC Compliance Examination Manual CRA Interagency Q&A July 2016