national disability institute real economic impact tour 2011 mayor ’ s leadership academy

Understanding the

Community reinvestment Act

Federal Reserve Bank of Atlanta CED

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National Disability InstituteReal Economic Impact Tour

2011 Mayor’s Leadership Academy

What Is CRA?2

CRA Statute --12 USC 2901 (Reg. 12 CFR 25)

1977: Congress passed the Community Reinvestment Act – Federal banking regulatory agencies issued Regulation BB to implement law.

Enacted to prevent redlining and to encourage financial institutions to help meet the credit needs of all segments of their communities, including low- and moderate-income (LMI) neighborhoods Including low- and moderate-income individuals and tracts. Including businesses/farms of different sizes and borrowers of

different income levels. Consistent with safe and sound operations.


What is CRA?3


Key Definitions Assessment Area

Each bank is evaluated on how well it serves its “assessment area”

Assessment area: Geographies in which bank has its main office,

branches, and deposit taking ATMs Surrounding areas where bank has originated or

purchased a substantial portion of its loans Must consist of “whole geographies”

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Key Definitions Performance Context

A bank’s performance is judged in the context of information about the bank and its Assessment Area, including demographic data on median income levels, distribution of

household income, nature of housing stock, housing costs and other relevant data

lending, investment and service opportunities the bank’s product offerings and business strategy, capacity and constraints,

past performance and the performance of similarly situated lenders the bank’s public file and any written comments about the bank’s CRA

performance any other relevant information

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Key Definitions

LMI

Low- and Moderate-Income (LMI) is based on area median income (AMI) of a geography, based on census data Low-income: < 50% of median income Moderate-income: 50% - < 80% of median income Middle-income: 80% - < 120% of the median income Upper-income: 120% or more of the median income

AMI - annual income figure for which there are as many families with incomes below that level as there are above that level For metro areas use the MSA’s Median Family Income For rural areas use the Statewide

Non-metropolitan Median Family Income

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Key Definitions Community Development

Affordable Housing for LMI individuals; Community services targeted to LMI individuals; Activities that promote economic development by financing

small business/farms. Area Revitalization and Stabilization

Low- or moderate-income geographies; Designated disaster areas; or Distressed non-metropolitan middle-income geographies Underserved non-metropolitan

middle-income geographies

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Key Definitions Qualified Investment

Lawful investment, deposit, membership share, or grant that has community development as its primary purpose

Examples: financial intermediaries that lend in LMI areas or to LMI

individuals in order to promote community development organizations that promote economic development by

financing small business facilities that promote community development in LMI areas

for LMI individuals projects eligible for low-income

housing tax credits.

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Types of CRA Examinations

Exam TypesSmall BankIntermediate Small Bank (ISB)Large Bank

http://www.ffiec.gov/cra/examinations.htm

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Small Bank Test

Banks with assets under $280 million

Exam Criteria:

1. Loan to deposit ratio

2. Lending inside and outside of the assessment area

3. Distribution of loans by geography

4. Distribution of loans by borrower income and revenue size

5. Responses to CRA related complaints

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ISB and Large Bank Test

Banks with assets between $280 million and $1.122 billion are “intermediate small banks” or referred to as “ISBs.”

Exam criteria: Lending Test Investment Test Service Test

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CRA Ratings

A bank’s record of meeting community needs is considered during an application review for a merger, acquisition, or branching

OutstandingSatisfactory (High Sat/Low Sat)Needs to ImproveSubstantial Noncompliance

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Good CRA Opportunities for Banks

Loans, services and investments that clearly benefit qualified populations and geographies.

Loans, services and investments related to community development activities .

For small banks, primarily Real Estate and Small Business Lending.

For large banks and ISBs, can be greater regional market that includes assessment area – more complex activities.

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What Banks Look for in Partners

CapacityProven PerformanceSustainabilityAssessment and ResponsivenessInnovation Target Market PenetrationRecordkeeping and Accountability

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CRA Challenges

Documentation of eligibility and impact.Capturing income data related to activities.Ensuring activities fulfill intended outcome.Training and technical expertise in development

programs.Adequate documentation for underwriting.Outreach to underserved and unbanked markets and

populations.Identification of banking and development

needs.

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Bank Decision Factors

Assessment AreaRiskCostResponse to assessed needBusiness/skill alignmentLeverageValue to overall CRA strategy/portfolioBusiness development potential

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Public File for All Institutions17

Full file at the main office and at one office in each stateLimited file at branch locations All written comments for the current year and two

previous yearsMost recent public evaluation List of all branches - address and geographiesList of services Map of Assessment AreasLast two years HMDA Disclosure Statement


Resources

FFIEC Community Reinvestment Act Pagehttp://www.ffiec.gov/cra/

FFIEC Guide to CRA Data Collection and Reportinghttp://www.ffiec.gov/cra/guide.htm

FFIEC Guide to HMDA Reportinghttp://www.ffiec.gov/hmda/guide.htm

Federal Reserve Bank CRA Guidehttp://www.dallasfed.org/ca/epersp/2007/4_2.cfm

FFIEC CRA Q & As 2009http://www.fdic.gov/news/news/press/2009/E8-31116.pdf

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Thank You

John Eric Nelson, Managing Partner

Wall Street Without Walls

[email protected]

Janet Hamer

Federal Reserve Bank of Atlanta

[email protected]

Kip Child

FDIC

[email protected]

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national disability institute real economic impact tour 2011 mayor ’ s leadership academy

Documents

median income levels

median incomemoderateincome

median incomemiddleincome

median incomeupperincome

area median income ami

msas median family income

moderateincome geographies

census datalowincome