Naturally occurring affordable housing (NOAH) are residential rental properties that are affordable, but unsubsidized by any federal program. The rents are relatively low compared to regional housing markets. From a CRA standpoint, we might be mining for community development loans, so it’s important to look at our commercial real estate portfolios, which may include NOAH.

Here, I cover the questions to ask while reviewing commercial real estate transactions. I also cover the two measures to use to determine if rents are affordable for low- or moderate-income individuals.. It’s important to work closely with your commercial real estate lenders to uncover transactions in a portfolio that would qualify as a community development loan.

• HUD Fair Market Rents: https://www.huduser.gov/portal/datasets/fmr.html 

• McKinsey & Co Report re Naturally Occurring Affordable Housing: https://www.mckinsey.com/industries/public-sector/our-insights/preserving-the-largest-and-most-at-risk-supply-of-affordable-housing

• OCC Community Development Fact Sheet re Community Development Activities: https://www.occ.gov/publications-and-resources/publications/community-affairs/community-developments-fact-sheets/pub-fact-sheet-cra-comm-dev-loans-invest-svcs-jan-2019.pdf

• CRA Today Website: https://cratoday.com/
• CRA Hub: For more Community Reinvestment Act training resources, check out the Hub! https://cratoday.com/hub
• Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/