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  • Comment Detail

  • Date: 01/25/23
    First Name: Deborah
    Last Name: Thompson
    Email: djst25@grmail.com
    Organization Type: fannie mae
    Organization: N/A

  • Comment

    Can a credit union that is a CDFI institution, but not considered a "small financial institution" (assets under $304M) originate mortgage loans in designated rural areas under the Duty to Serve initiative?
    What all in included in "assets" to determine the $304M? The definition I found from 1271.1 CFR - Assets includes furniture and equipment, leasehold improvements, and capitalized start-up costs.
    If the goal is to lend in under served areas within the Duty to Serve criteria, why is the size of a financial institution in that area an issue? I understand about the consolidation of banks and the loss of bank branches and the economic impact on those areas, but the goal is still to increase home ownership in those rural communities.
    Thank you