Welcome to the CRA Podcast. I’m Linda Lewis Ezuka, your host and Founder of CRA Today and the CRA Hub. This podcast is part of my mission to transform communities through the power of economic development and the Community Reinvestment Act. For a deeper dive into community development concepts, join your CRA colleagues in the CRA Hub, a membership for bankers to connect and master the art of the CRA. www.cratoday.com/Hub www.cratoday.com
NCRC Community Development Fund, a subsidiary of the National Community Reinvestment Coalition, lends primarily to Black, Latino, women, and immigrant entrepreneurs and business owners throughout the country with its mission to help bridge the racial wealth divide by supporting entrepreneurship and affordable homeownership in America's underserved communities.Its new lending platform – for which it is also building an algorithm to determine loan eligibility – stands to make the roughly 10-person operation more efficient, Marisa Calderon, NCRC CDF's executive director, said in a recent interview.This episode of the CRA Podcast addresses the promise of CDFI lending, partnerships with financial institutions to support the continuum of capital for disadvantaged communities, and how the Community Development Fund is also building a new lending platform leveraging AI to not only support efficiencies in their operation but also for others in the CDFI industry. Marisa Calderon's Bio and ExperienceMarisa Calderon is an experienced executive who is regularly recognized, awarded and cited nationwide for her expertise in the housing and financial services industries. She has over two decades of experience dedicated to the issues of economic mobility and bridging America's racial wealth gap. Marisa Calderon is the executive director at NCRC Community Development Fund (NCRC CDF), a nonprofit, U.S. Treasury-certified community development financial institution (CDFI) that provides loan capital to expand access to affordable homeownership, which helps Black-, Brown- and woman-owned businesses thrive. Under her leadership in her first 18 months at NCRC CDF, they deployed over $17 million in capital to historically underserved Black, Latino, immigrant, and women entrepreneurs through their small business and investment programs, earning them a place on Fast Company's list of 2022 Most Innovative Companies in the World. She is also chief of community finance and mobility at the NCRC CDF's parent company, the National Community Reinvestment Coalition (NCRC), where her work focuses on advancing economic mobility for communities impacted by systemic inequality and disinvestment. Marisa is ranked on the Swanepoel Power 200 as one of the most powerful leaders in the residential real estate industry, and was twice named a HousingWire Woman of Influence in 2018 and 2021 for her work in increasing real estate and mortgage professionals' understanding and appreciation of the Hispanic home-buying market. In 2021, she was named one of Diversity Journal's Women Worth Watching in Leadership and was featured in Hispanic Stars Rising: The New Face of Power and was recognized on Women We Admire's list of the Top 50 Women Leaders in Finance of 2022. Frequently sought out as an expert on affordable housing, lending and immigration, Marisa has been interviewed by numerous publications and media outlets, including NPR's Marketplace and does regular public speaking at industry and general market events, including Mortgage Banker's Association, FDIC, Consumer Federation of America, National Fair Housing Alliance, and many others. In addition to this work, Marisa is also a board member of the non-partisan political action committee, Latinas Lead California and a Senior Advisor to America's Homeowner Alliance.CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.
This episode of the CRA Podcast highlights the community development work of Joshua Kummer of Bankers Trust. Joshua is the bank's CRA and Fair Banking Officer overseeing the bank's Fair Banking Program, which includes CRA, Fair Lending, HMDA, UDAAP, and Complaint Management. You will find Joshua to be very passionate about this work and this episode shares the high impact community development partnerships he has forged within his community. Not only does he have the heart for this work; you will also hear how his passion and drive has helped Bankers Trust sustain an Outstanding Community Reinvestment Act (CRA) rating!Here are the programs that are referenced within the episode:Community Development Financial Institutions (CDFI) Involvement Iowa Community CapitalSolidarity Microfinance is a non-profit program of Iowa Community Capital to create economicopportunities through small business loans, training and support, and savings services.ICC's Solidarity Microfinance program provides small loans of $500 to $8000, savings services, and financial learning opportunities for eligible low-income entrepreneurs in the Greater Des Moines Metro Area. The Solidarity Microfinance program uses Grameen peer-group lending methodology and targets women entrepreneurs from diverse new resident cultures. Neighborhood Finance CorporationNFC provides unique lending programs and other services to facilitate neighborhood revitalization in Polk County and Cedar Rapids, Iowa through partnerships with residents, governments, community-based organizations, lending institutions and the business community. For more information on our programs and services, please visit our Loan Programs page. NFC is a proud Chartered Member of NeighborWorks America. TrellisTrellis (originally started as Neighborhood Housing Services of Phoenix) was formed in 1975 with help from the City of Phoenix and NeighborWorks America. NeighborWorks America is a national nonprofit organization, federally funded by appropriations from Congress that provide financial support, technical assistance and training for community-based revitalization efforts in all 50 states.Access to homeownership is for all of us. Individuals and families become stable and more economically secure; neighborhoods become vital, active communities; and cities gain jobs and tax revenues. It's an investment with positive returns for everyone. Other Community Involvement InitiativesHOME, Inc.HOME, Inc. is the oldest private nonprofit housing organization in Des Moines. Our mission is to meet individuals and families where they are in their housing journey. We surround our clients with compassion, support, and education so they feel empowered to make a safe, stable home for themselves or their family. To accomplish our mission, we…– Provide counseling and education to help people become successful homeowners, landlords, and tenants.– Develop, rehab, and build affordable housing units.– Help families through counseling and education to become homeowners. Newtown Community Development CorporationOur mission is to help people improve their financial well-being while strengthening communities through education, counseling, coaching, and the development and stewardship of permanently affordable homes.Newtown Community Development Corporation (Newtown) is a Tempe-based nonprofit founded in 1994. Newtown is recognized throughout the Phoenix Metro Area as a leading provider of homebuyer education, homeownership counseling, credit counseling, financial coaching, financial literacy education, and down-payment assistance. Newtown is a HUD-Approved Housing Counseling Agency and adheres to national industry standards for homeownership education and counseling. Services are provided in English and Spanish.Newtown also operates an innovative Community Land Trust, which builds and renovates permanently affordable houses, providing successful homeownership opportunities for generations of lower-income families. Created in 2001, Newtown's Community Land Trust is the largest in Arizona with homes across Maricopa County.BIOJoshua Kummer is the AVP, Fair Banking Officer at Bankers Trust; Iowa's largest privately owned bank headquartered in Des Moines, Iowa with assets totaling over $6 billion. The bank operates branches in Central Iowa, Cedar Rapids, IA, and Phoenix, AZ, as has offices in Omaha, NE and Sioux Falls, SD. Joshua started his banking career over 11 years ago as a part-time teller while attending college. Since then, he's held various positions including Personal Banker, Sales & Service Manager, Branch Manager, CRA Officer and now Fair Banking Officer. He holds two compliance-related certifications: Certified Community Bank Compliance Officer (CCBCO) and Fair Lending Expert (FLE). He is also involved in his community and currently sits on the Neighborhood Finance Corporation Board of Directors, Greater DesMoines Habitat for Humanity Access to Credit Committee, Iowa Bankers Association DEI Committee and Special Olympics Iowa Fundraising Committee. Joshua has a passion for ensuring customers receive fair and equitable treatment while banking with Bankers Trust and advocates for those with limited financialresources. Bankers Trust: As Iowa's largest privately owned bank, Bankers Trust serves the personal and business banking, lending and wealth management needs of our community.Bankers Trust Core Value: CommunityWe will strive to be the best corporate citizen by supporting diverse community organizations, both financially and through employee volunteerism. We invest in the community by nurturing and encouraging growth, stability and continued success.
Hi, it's Linda with CRA today and the CRA Hub. I thought I'd hop back here and give you a quick tip. So many of you have asked "what exactly is BLS (hint, it is the Bureau of Labor Statistics) and how should I use it to support my CRA program?" Well this month in the CRA Hub, we're focusing on CRA exam prep. As you know, it's really important to make sure that we are crossing our T's and dotting our I's and making sure that all of our community development activities are properly documented. Well, this is where the website bls.gov comes in. This website will help you substantiate the creation or retentions of jobs for low and moderate income people. The BLS website is where you can go to create the documentation or the proof, to show your examiners during an exam to substantiate community development loans and activities, as applicable. So let's take a $1.5M community development loan that your bank originated to a restaurant to expand to a new location. You would first document that the borrower is considered a small business and then you will need to document and prove that the majority of the jobs created as a result of your financing would in fact be jobs for low and moderate income individuals. Given my description so far, you may know you are working towards documenting this community development loan under the economic development hook, right? So after you document all other aspects of the community development loan and you are down to documenting the creation of jobs for LMI individuals. So you go to BLS.gov and you search for jobs that typically would be found in a restaurant, like cooks, waiters, bartenders. I tend to keep two or three, as an example is my backup files for examiners. And then you can drill down to the different geographies within Bureau of Labor Statistics (BLS). So I recommend getting as close as you can to the geographic location of the business that you are documenting the community development loan for aka “follow the money” to the community development impact.Here is the link to the screen share overview of BLS.gov: https://www.loom.com/share/2ae5b997547343a2b33ce9413db17598You would take these representative jobs and compare the salaries against area median income to make sure these annual salaries fall below the thresholds for a moderate-income person in the area for which the loans proceeds are applied. I hope this helps you as you continue to mine for community development loans and then also document your CD loans. I often say, if it's not properly document, it didn't really happen! The “art of the CRA” as I say is to properly document all of your activities to support an efficient review by your examiners and this “pre-work” if you will will also allow you to defend your position with confidence. CRA Today provides Community Reinvestment Act Training, Professional Development, and a new Certification for CRA professionals. We Help You Master the CRA, Get Exam-Ready, and Reinvest for the Greater Good.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn: https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.
CRA Podcast Episode 16: Community Development Loans Demystifiedwith Krista Shonk, VP & Senior Counsel, Regulatory Compliance and Policy, Fair & Responsible Banking, ABAAre you one of the 95 percent of banks that are underreporting community development loans under the Community Reinvestment Act (CRA)? This episode debunks the myths around how to recognize community development loans at the time of loan origination and how to avoid expensive loan mining activities at the tail end of your compliance processes.Community development loans are the most heavily weighted aspect of the CRA, and when you understate your community development loans you are compromising your bank's lending performance. As you know, if you don't meet the credit needs of your communities, it can lead to public relations risks that could even result in an internal “needs to improve” rating or hamper your ability to adjust your bank's strategy priorities.ABA's Krista Shonk interviews Linda Ezuka of CRA Today in this focused episode on the most subjective aspect of the CRA. Identifying community development loans requires many internal stakeholders within the bank and this episode highlights a solid approach to engage commercial lenders in identifying loans that are hidden within their portfolios and their loan pipelines. Most lenders are focusing on meeting the credit needs of their commercial clients and overlook common community development loans due to a lack of understanding of the CRA. The key to engaging commercial loan officers is to conduct community development loan training. Use this training to highlight the community development "hooks" or pillars to determine if their loans meet the primary purpose test.Ongoing micro-training moments are key to keep community development loans top of mind thereafter.Enjoy this episode that breaks down strategies to identify community development loans at origination and how to avoid underreporting these important loans. If you want to take a deeper dive into this work to learn how to increase your community development loan portfolios, consider our community development loan workshop of customized bank training for commercial loans officers. See below for more information. Links: Community Development Loan Workshop: https://cratoday.com/workshop/ Customized Bank Training: https://cratoday.com/cra-training/ Check out our website to take the next step in your CRA journey today: www.cratoday.com Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.
Are you looking to take your community development services to the next level? If so, don't underestimate the breadth and depth of internal expertise that lies right at your fingertips. Your bank is likely full of subject-matter experts that can enhance your existing services or perhaps even build out an entirely new external partnership.While banks typically engage mortgage officers, lenders, and retail team members with opportunities to teach financial education in the community, other departments have a wealth of technical expertise to offer. Employees' technical expertise in core business functions can result in the creation of deliverables at the end of a short project (i.e. creating a social media strategy, designing a logo, conducting a technology assessment) or can result in actionable recommendations. Think of your employees as pro-bono consultants. For example, consider how you might leverage the internal expertise found in these departments to drive the positive and meaningful impact your organization has on the community. (Ensure the benefitting organization meets one of the four community development purposes!)• Compliance: Serve as a subject-matter expert at a small business fraud prevention workshop or a consumer protection workshop (identify theft, fraud prevention, common types of financial exploitation, etc).• Human Resources: Teach on workforce development topics such as resume prep, interview tips. Serve on an advisory board for a nonprofit focused on financial service career pathways for LMI individuals. Consult with an organization as they develop an employee handbook.• Marketing: Create collateral (brochure, etc.) or a logo pro-bono for a local nonprofit. Help a nonprofit or small business develop a social media strategy.• IT: Serve on an advisory board for a nonprofit focused on financial service career pathways for LMI individuals. Conduct a technology assessment for an organization. Assist with the installation of new software/hardware.• Accounting: Provide assistance on accounting/bookkeeping. Help organizations review internal controls and policies.• Legal: Review contracts, etc. pro bono.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn: https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
There are a wealth of opportunities to serve aspiring entrepreneurs and established small businesses!Consider the following opportunities to diversify your portfolio of existing community development services and ensure that some of them meet the “Economic Development” community development purpose.• Contact your local CDFIs and other small business development nonprofits and inquire about committee or board openings. Some might even have opportunities for lenders to serve as mentors to local entrepreneurs or to serve on a one-time committee that provides constructive feedback on the entrepreneurs' business ideas. • Reach out to local Small Business Development Centers and see if one of your lenders can teach a class or serve on a panel about accessing capital. Consider inviting a credit union, a CDFI, and another type of bank to join the panel as well. Each one will have a unique perspective to provide!• Volunteer with your local SCORE chapter, where opportunities include serving as a Business Mentor, Subject Matter Expert, Local Workshop Presenter, and more.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
After collecting information about existing employee involvement through board service and volunteerism, it's apparent you need to increase your bank's community development services…but where do you start?First, look at your bank's existing community development services and consider whether you can expand or deepen that relationship by providing additional services. Is the organization looking for new board or committee members with financial expertise? Could their clients benefit from financial capability workshops or workforce development support such as resume reviews?Second, are there local affiliates of national organizations that you might be able to support in each of your assessment areas? Through Junior Achievement your employees could teach a curriculum focused on financial literacy and career readiness in local schools with free-and-reduced-lunch rates greater than 51%. Through Habitat for Humanity, an employee could review homeowner applications to ensure applicants can afford the mortgage while serving on a Family Selection Committee. Third, don't be afraid to get creative! Consider meeting with the local community foundation or United Way chapter to learn about the greatest needs in the communities you serve. Oftentimes these organizations are the first to know about board or committee opportunities in the community and can direct you towards organizations that serve low-to-moderate-income individuals or small businesses and that align with CRA community development purposes. The sky is the limit to what you could build together! For some inspiration, read the OCC's Financial Capability Fact Sheet. https://www.occ.gov/publications-and-resources/publications/community-affairs/community-developments-fact-sheets/pub-fact-sheet-financial-capability-jan-2019.pdfCRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
I predict that at least 90% of banks under report their community development loans. Yes, that's an alarming statistic, but I believe it's true. As I often say, the art of the CRA is not creating new programs, but actually unveiling what your bank is already doing to meet the needs of your community by the nature of opening your doors and deploying your core banking services. Recently, I have been conducting many customized bank training sessions for commercial loan officers. We use the bank's credit approval memorandums and take a deep dive into originated loans to reveal hidden community development purposes. It's fun! The look on their faces when they realize they originated community development loans and they didn't even know it! It's priceless. I also offer a follow up Q&A session where the loan officers get to review their pipeline with me and ask me anything. Again, like magic, there are more community development loan prospects on the table. Here is what a senior commercial lender shared… “Linda's webinar provided CRA/CDL training that gave us the depth of knowledge to more accurately identify opportunities that we had been missing for years. Past trainings left us with more questions than answers. Her presentation was customized to our needs and our commercial lending team dealt with actual loans that we selected. We also had the opportunity to ask experience based questions and receive in depth answers that opened people's eyes. Since the webinars, we have taken a deeper dive into our loan closings since our last exam and found numerous cases of economic development and affordable housing loans that had not been reported. Very well worth the time and cost that will pay dividends over the years.” ~Chuck Woerner, SVP , Senior Commercial Lender, Fairfield County BankYou don't need me to do this training, but if you have too much on your plate, this is a good option too. Either way you approach this training, it is imperative to have a strategy in place or you will be underreporting your community development loan portfolio which compromises your lending performance and your overall CRA rating. What do you have planned to engage with your commercial lending officers? Make sure you outline a solid strategy to build these critical relationships and support them in identifying community development loans. The return on your investment of time is priceless! CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
A key element of your CRA program is understanding that CRA is not always about creating new opportunities, but is about finding the opportunities that already exist. To do this, you should aim to give each team at least three CRA trainings a year. This will keep team members up-to-date on any new regulations and will help keep your program top of mind. Team members are more likely to forget about CRA when they haven't heard from you in a long time. But if you train team members to watch out for CRA opportunities, you're almost guaranteed to come across new services, loans, and investments that are eligible for CRA credit. So who do you train, you ask? It depends on your bank size and structure, but here is a common list of trainings: New Hire Training: The first introduction to CRA, do this in person or recorded, keep it quick and high level. CRA Essential Live - https://hub.cratoday.com/freewebinarBankwide Training: Keep this high level and part of your LMS (your learning management system). Highlight how everyone has a role in the CRA program (service etc). Commercial Lending Partners: This includes small businesses, commercial lending, commercial real estate, all aimed to help you identify community development loans! You can do this yourself or I also help train commercial loan officers using their own credit documents! -https://cratoday.com/cra-training/ Don't forget loan ops too, not only for community development loan identification, but also for data integrity training! - https://cratoday.com/blueprint/Other departments include Marketing, Investments, Controllers etc. The list can go on and on! The bottomline here is you need to have a solid training plan in place based on your bank size and plan to deploy training on a periodic basis. And don't forget to keep it light and fun! CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
“One of the things that are appealing to me about being a Community Reinvestment Officer is helping those who are underserved,” says Melvin Hugans, a Community Reinvestment Officer at Thomasville National Bank. In honor of National Financial Capability Month, where financial institutions and organizations support programs that promote economic empowerment, host Linda Ezuka interviews Melvin Hugans on his life as a CRA officer. A retired elementary school principal with a history of non-profit community work, Melvin is now on a mission to educate America's youth on the benefits of financial literacy.With debt on the rise in America, people need financial literacy more than ever. Understanding this all too well, Melvin works to educate young people on how they can start saving and create spending plans now. Through Thomasville National Bank, a company whose mission is to promote economic development in their community, Melvin can continue doing what he loves while bettering the lives of others. Tune into this week's episode of CRA Podcast for a meaningful conversation on financial literacy education. Learn more about Melvin's transition into the CRA profession, how Thomasville National Bank serves its community, and the importance of staying committed to your mission all year.The Community Reinvestment Act (CRA) encourages banks to invest in and deploy financial literacy efforts in their communities. If you would like to learn more about the intersection between banks, the CRA, financial literacy, and how to join their efforts, visit the Community Developments Fact Sheet from the OCC. Financial capability resource from the Office of the Comptroller of the Currency.Melvin Hugans has served as the Thomasville National Bank Community Reinvestment Officer for 2 years. He has a long history of involvement in community non-profits in the communities where TNB branches are located. Prior to assuming the role as the Community Reinvestment Officer, Melvin retired as an elementary school principal. The relationships he established as a principal have helped him grow in his role as a community reinvestment officer. TNB is a regulated by the OCC and has 1.3 Billon dollars in assets.Links:Thomasville National Bank: https://tnbank.com/about-usCommunity Developments Fact Sheet: https://www.occ.gov/publications-and-resources/publications/community-affairs/community-developments-fact-sheets/pub-fact-sheet-financial-capability-jan-2019.pdfFor more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
“11% of students from low-income households graduate college,” says Abby Coyle. As a former educator for Teachers for America, Abby realized the equity gap in the education system. To close the gap, Abby co-founded ClassEquity, an online platform aimed to help students build financial literacy. Class equity enables students to open their own "bank account," through which they practice earning classroom dollars, saving, and spending in a safe environment. Co-founders Abby and Katie started ClassEquity to solve a problem they both experienced during their time as classroom teachers in Title 1 schools: access to financial education. With ClassEquity, they aim to increase economic mobility by giving all students the tools they need to become financially independent, regardless of their zip code. After launching this fall, ClassEquity now supports over 3,000 students across 120 classrooms weekly. Tune into this episode of the CRA Podcast to learn more about the role that technology and financial education play in providing economic and educational equity for students. Links: Links to program: ClassEquity.com; Blog; LinkedIn pageContact info: abby@classequity.comFor sponsorship opportunities, interested parties can email me at abby@classequity.com For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
April 1st marked the start of National Financial Capability Month, a month during which organizations (especially financial institutions!) across the country focus on supporting programs that expand financial literacy, economic empowerment, and access to capital and credit for all consumers. You might be asking, “As a bank, what can we do to build financial capability in our community?” Luckily, there are many pre-existing resources just waiting for you to use! Here are a few:• FDIC's Money Smart – Consider this the Swiss army knife of financial capability resources. It provides a range of curriculum options tailored for young people (K-12), young adults (12-20), adults, older adults, and even small businesses. Note that some modules are long (2+ hours); adapt them in partnership with the nonprofit to best suit the needs & interests of your audience and to fall within time constraints.https://www.fdic.gov/resources/consumers/money-smart/index.html• The Federal Reserve Bank of Dallas's Building Wealth – A 5-module curriculum available in multiple formats. https://www.dallasfed.org/~/media/microsites/cd/wealth/index.html• Consumer Financial Protection Bureau – Pull together educational tools for key financial decisions, search their database of 270 financial literacy activities for youth, or download publications for youth and adults available in PDF or print format.https://www.consumerfinance.gov/• American Bankers Association – ABA has various ready-to-teach presentations and activities in connection with their various community programs, such as Get Smart About Credit, Teach Children to Save, and Safe Banking for Seniors. https://www.aba.com/For a comprehensive list of useful financial literacy resources, issues, and events, visit the OCC's Financial Literacy Resource Directory.occ.gov/topics/consumers-and-communities/community-affairs/resource-directories/financial-literacy/index-financial-literacy-resource-directory.htmlCRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
For the last thirty years, Tawalla Simmons has dedicated her career to serving others through CRA-inspired programs. Today, she is the president of Inspiring You to Greatness, a 501(c)3 nonprofit dedicated to educating low to moderate-income members of the community about credit, mortgage, and money literacy. As a previous mortgage broker, Tawalla saw firsthand the gap in education surrounding topics such as credit, job readiness, and housing stability. To better serve the community, Tawalla put together a platform of CRA-eligible programs that provide the necessary tools to both increase mortgage approval rates and teach community members how to be successful in the workforce. As the president of IYTG, Tawalla hopes to one day be a primary resource utilized by banks across the country. Tune into this week's episode of the CRA Podcast to learn more about the importance of strengthening your basic life skills, community development, and how you can achieve personal and professional growth through IYTG's online educational programs. Call to Action: Inspiring You To Greatness CDC would like to be one of the resources utilized by banks when they need to begin the bootstrap serving in the census tracts and communities we currently serve. We provide bank approved CRA eligible online classes with certificates of completion, demographics, zip codes, income information, and data collection tools to ensure CRA examinations are Satisfactory. Links: Tawalla Simmons, President, Inspiring You to Greatness CDCEmail: tsimmons@iytgcdc.orgWebsite: www.iytgcdc.orgOnline Academy: www.iytgcdc.com www.gocoacht.teachable.com Inspiring You To Greatness CDC Educational Academy supports CRA Community Reinvestment Acts of Service in Communities by offering Social Services, Financial Literacy, Credit Education, College, Career, Mortgage Readiness Certificate of Completion Classes through an online platform helping non-profits, banking partners, businesses, and clients connect for the greater good.Inspiring You To Greatness CDC Educational Academy courses assist clients with taking classes in a busy environment, helps banks by offering CRA eligible online courses, while helping other nonprofits streamline social services through our platform.For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
It's time to build your 2022 CRA strategy and action plan! Here are your next steps: Sign up to download the CRA plan resource. This list of questions will help prompt you as you start to build out your CRA plan. https://hub.cratoday.com/opt-in-c71cd533-9b19-4d80-89d9-43b2ec44f869 To prepare your approach, start by obtaining a copy of your bank's strategic plans for 2022, if available. If a document is not available to you, set up meetings with your executive management team members to learn more about the core strategies of the bank and how you might integrate those priorities into your CRA plan. Next, meet with business units to learn about their business goals and discuss how your CRA program might also support them in their business goals. You can also set benchmarks for identifying community development loans within the commercial lending departments and divisions.You might also want to meet with marketing to make a stronger link between your CRA program and their key priorities as well. Typically CRA programs incorporate marketing goals as it relates to CRA service goals and charitable giving initiatives. Compile all the details into one document and set benchmarks and timelines to pave the path forward for an effective CRA program. Don't forget that it doesn't have to be perfect, you just have to get it started! CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts, and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Build your CRA plan. You aren't required under the Community Reinvestment Act to build a plan, but it's an industry best-practice and will help take your CRA program to the next level. Keep your plan simple and don't worry about making it perfect. Your plan can be one page or it can be 20; everything is up to you. As a general rule, you should start your plan with an overview of your CRA program. Where are you in the exam cycle? Who's your regulator? What are some of the past year's accomplishments? Next, list out your bank's strategic priorities, both long and short term. Include your CRA performance goals, and make sure to mention goals for your lending, services, and investment tests (including benchmarks!), as well as goals for fee and investment income, deposits, and various business units. This is where you can set business unit goals, community development activity benchmarks and the like. This document represents your path forward. Some sections you might include are how you're going to conduct CRA training, any applicable regulatory changes, technical compliance, public relations, and marketing. For a list of questions to ask yourself when building your CRA plan, sign up for the PDF download here: https://hub.cratoday.com/pl/2147559089. This will help you think about your CRA program and build that perfect plan to promote your program and make a difference in your community. Most of all, remember that your CRA journey is your CRA journey. Don't make it more complicated than it needs to be, and have fun with it. Once you've created your CRA plan, you can share it with executive management, internal business units, the compliance department, and even CRA examiners. This will help keep everyone in your bank on the same page and set expectations throughout the company.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Data submitted…now what? Now that you are confident in the reliability of the data, revisit your goals for the new performance year. It's never-ending, I know!First, you'll want to align your CRA strategy with the bank's corporate strategy. As a member of the CRA team, you're responsible for leading programs and building support in the community that helps your bank connect with potential customers. As such, key stakeholders and the executive management team should see you as a key player in carrying out the bank strategy. Before you can build your own CRA plan or strategy, it's important to consider the bank's corporate strategy and priorities. Once you understand the bank's key initiatives, you can align your CRA program's priorities with overarching corporate directives to impact the entire institution and the community. To learn about your bank's key initiatives and corporate strategy, meet with the appropriate people and discuss. Ask how your CRA program could support the bank, and make sure to tell them how they might help your CRA program. Next, you'll want to consider all elements of your CRA program. When planning and outlining your CRA strategy for 2022, you need to keep all elements of your program in mind. Here are some things to consider:• Collaborate with different business units to ensure you're meeting the credit needs of the community. • Engage key internal bank stakeholders to maximize the bank's community development services, loans, and investments.• Create a system to ensure technical compliance with all required deadlines and activities associated with public file, public notices, sunshine provision reporting, etc. • Acknowledge where you are in the CRA exam cycle. Your priorities will shift depending on whether you're in year one of your exam cycle or if your exam is coming next quarter.• Develop a plan to train key internal stakeholders such as commercial loans officers, retail staff members, and CRA team members embedded in different departments.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Why does February only have 28 days? It seems so wrong as we are up against our March 1st CRA data reporting deadline! For those of you with CRA data reporting requirements, by now you have filed or might be working the weekend to prepare your small business, HMDA and community development loans data for FRB submission. Since time is of the essence, I recommend you do a "hail mary" last minute data integrity review to mimic a data integrity exam, much like what our examiners will do on-site prior to a full scope CRA examination.https://kajabi-storefronts-production.global.ssl.fastly.net/kajabi-storefronts-production/themes/1621312/settings_images/KjOTyo8DTGOZ0El5W7Po_Screenshot_2020-02-28_07.25.24.pngAs many of you have experienced, and may have already integrated into your compliance management system, periodically sampling your data is a cornerstone of ensuring CRA data integrity. If you haven't mimicked a CRA data integrity exam lately, use the link below to remind your team how to follow the FRB's approach to data sampling. And, if things "go south" post review, data resubmission instructions are included, too! These data resubmission instructions are geared for data-integrity exams, but can be used as a guide to determine if you want to resubmit during your annual filing process before the data is aggregated and available for public consumption.Consumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdfBe sure to report your findings and your specific recommendation to executive management.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
As you know, time is ticking away and soon you will be faced with scrubbing your CRA data to ready your small business, HMDA and community development loans data submission. Over the next few weeks, we will cover the most common mistakes and will provide some guidance to support you on your road to CRA data integrity. Here are four of the mistakes most commonly made by banks regarding their CRA data: 1. Reporting Non-Reportable Loans• Ensure loans reported meet the size and definition tests• Check loans to non-profits, only some are reportable• Follow the rules for refinance/renewal loans• Review loan lists to ensure all reportable loans are reportedFFIEC's Guide to CRA Data Collection and Reporting: https://www.ffiec.gov/cra/default.htm 2. Incorrect Loan Amount• Check records for appropriate loan amount, specifically focusing on:• Refinances/renewals• Credit line increases/decreases• Typographical errors/transposing numbers/rounding3. Incorrect Loan Location• Ensure the correct address is used; request street address• Create a reliable backup system if address was not identified• Watch for typographical errors, transposing numbers, rounding• Update systems with FFIEC Census file geographic changes, check for the correct year4. Incorrect Gross Annual Revenue (GAR)• Ensure that gross annual revenues or income was reported instead of net revenue• Ensure that aggregated revenues were reported if the underwriting relied/considered additional entity revenues• Double check if the credit file contains revenue information, and if so, report that revenue even if there was no reliance on revenue in underwritingQuotes• “Triple check reporting loans to make sure that they are in fact reportable and that you report the correct loan amount, correct loan location, and the correct gross annual revenue.” (06:45-07:00)CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Let's refocus our time on your CRA data integrity and, for some of you, your annual CRA data submission. For small and intermediate small banks, this means making sure your data is collected and maintained for future examiner review. For large banks, this means readying your data for FRB submission! By now, you are well on your way to testing, sampling and double checking your HMDA, small business and community development loans. Speaking of community development loans, have you finished scouring your loan originations to mine for additional community development loans that may have been overlooked? In the perfect world, your loan officers would be involving you in community development deals at the prospecting phase through origination or at least providing you with a credit approval memorandum or a heads up that they just closed a community development loan that you should take a look at! Just in case you are still working through this, here are three approaches you might want to consider as you continue to prepare for the March 1st deadline. #1 Economic Development Hook: When reviewing a credit approval memorandum for a potential economic development qualified community development loan, SBA size standards are commonly used to determine if a borrower qualifies as a small business. Unlike the "gross annual revenue" definition in small business reporting, the NAICS size standards use a different measure defined as "annual receipts." This enables you to generally qualify more businesses as "small" and thus more potential community development loans. Click this link to learn more: https://www.sba.gov/sites/default/files/2019-08/SBA%20Table%20of%20Size%20Standards_Effective%20Aug%2019%2C%202019_Rev.pdf#2 Check 2021 Double Check Loans for Renewals: Remember renewals generally count, so I double check my list for any "low-hanging fruit" as long as the community development purpose remains. Click this link to reference the Q&A: https://www.govinfo.gov/content/pkg/FR-2016-07-25/pdf/2016-16693.pdf§ ll.42(b)(2)—5: Should institutions collect and report data about community development loans that are refinanced or renewed?A5. Yes. Institutions should collect information about community development loans that they refinance or renew as loan originations. #3 Defending Community Development Loan Impact: Although not required to file, it is imperative that a folder is created for each community development loan that will be reported in the aggregate. This is a tedious task, but essential when regulators are on-site testing for impact. It's easy to push this task into the future, but trust me, it's a monumental task if left to the last minute with other competing priorities of onsite examination preparation. Don't let this slip, and if you need to take an extra few weeks after the filing deadline, then do so... just don't wait until the end of your exam cycle!Quotes• “I estimate that over 90% of banks underreport their community development loans.” (02:21-02:28)CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Let's say you don't get to add to your CRA staff. What can you do to accomplish all of the work that you have before you? Today, I have three ways to support and supplement your CRA program. Leverage Bank Trainee ProgramsChances are there is a trainee program at your bank, whether it's for new officers of the bank, credit training, retail staff, etc. Oftentimes, these trainee programs have special projects you can vie for in your CRA program. You can provide either a special, one-time project OR a credit activity that they can embark upon during each training session to learn more about the bank.So, it's a win-win, right? Your bank trainees are very eager. Make sure you train them on the core CRA and community development loan identification concepts, and they can help identify community development loans. They can also help with:• Documentation, if you haven't had time to cross your T's and dot your I's• Data integrity reviews• Desktop procedures• Self-assessments or performance contexts for performance gaps you might haveSo, really think about this in terms of a case study, do some training, run some challenges, have a little fun, and make your training program a way to supplement your resources to support your CRA program.Hire InternsMany of our banks have intern programs, and you can have the interns do the same activities. Now, if you have some restrictions on the reporting or the sensitivity of client information, you can just have them do more external research and not have them look at credit documents. But, oftentimes we have our interns sign non-compete and confidentiality disclosures as well.Outsource to Consulting FirmsThe third way to support your CRA program is through outsourcing. We often use outsource consulting firms to help us either mine for community development loans or check the validity of our data on a quarterly basis. While you may be looking at loans at a hundred percent, these firms can provide independent, sampled reviews. Sometimes, you can even have consultants create self-assessments on your behalf.So again, leverage your trainee program within the bank, consider interns within your intern program and consider outsourcing to the extent that you need even more help that's specialized. CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
So, how do you actually build the culture of compliance within your bank?When you're looking at identifying your internal stakeholders, you'll want to look at the small business department, loan ops in particular. You could look at your home mortgage department, since they also have a loan ops group that touches the data on a daily basis as they originate loans. You also have your commercial lenders, your marketing and retail groups, and your investments and treasury divisions. These are all major stakeholders in ensuring that your bank meets the credit needs of your community and that you're able to run a safe and sound CRA program. It's really important that you look at all of these lines of businesses and then move the mark and build a culture of compliance.You would start by looking at executive management and making the case for more support from the line. You absolutely have to receive management buy-in to move forward. You can outline the expectations that you're hoping to support through working with a small business.You must also address the capacity issues. Everybody feels like they have an overwhelming plate of tasks, duties and job responsibilities. So, you must address this with management at the very start, so that you can be mindful of everyone's time and efficiently rebalance job activities. You must also commit to training as much as is necessary to support a smooth transition and ensure data integrity over time.You'll definitely have to play a leadership role in the training of your new stakeholders and lines of business, the key people that are supporting your CRA program. You'll also want to create your policies and procedures that then relate to the CRA. So, if it's in their job description and they're playing a role in the CRA program, you'll want to make sure that it's evidenced in the CRA policies, procedures, and desktop procedures for the work that they do. You can also create incentives, so that these stakeholders are inspired to do more. You always want to involve the lines of businesses as you continue to grow your CRA program, so that it's truly the bank's responsibility in your building up the CRA program as a team.Quotes• “You'll provide a lot of leadership, but it'll pay off by having a second set of eyes and more resources to support your CRA program.” (05:35-05:43)CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
So, how do you best go about dividing and conquering the work of a CRA officer? Many people inherit the CRA program and still have compliance responsibilities or dabble in BSA or share the titles of CRA officer and fair lending officer. Usually if you're just a team of one or even a partial position, you really have to do it all. From CRA data collection to data integrity testing to lending performance analytics to collecting service, investment and community development activities….the list goes on and on.Many people try to, as they grow over time, advocate to add to staff. So when you do that, this is how you might determine to divide and conquer. So as a CRA officer, you would keep some of the core responsibilities of your job, like CRA data strategy, goal setting, executive management engagement and, of course, working with compliance and risk management at a higher level. For CRA data integrity, you would continue monitoring your performance analytics blending service and investments, engaging with the lines of businesses, looking for and managing the exam prep activities and navigating regulatory change.And when you are able to “add to staff” and hire a CRA program administrator, or CRA deputy officer, the duties rebalance. You could have this person take on the data integrity aspects of extracting lending activity from your core system input, scrubbing it and importing into a CRA proprietary database. They might also do the first review and then you do a test review of the CRA data integrity.The CRA administrator would collect all the service activities and investment activities, and they can mine for community development loans. They would be creating the lists, the spreadsheets, or inputting into cadence software. They'll also be responsible for the technical compliance aspects of the CRA and managing your policies and procedures. So, there are definitely ways that you can delegate work between a CRA officer and an administrator to support your CRA program.I hope this helps at least differentiate how you might add to staff so that you can start to create your business case, to add an FTE to your team, to your mighty team of one.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Let's say you can't “add to staff” given resource constraints and you have to remain a mighty team of one doing “all of the things.” Sometimes you might feel like throwing in the towel…but not so fast! I have a few ideas for you. One common option is to engage with your line of business (LOB) management and team members to expand your internal CRA resources. You'll have to engage and inspire your LOB team members to get involved. This takes a while and requires you to build a culture of compliance throughout your institution. As you know, CRA is not a one-man job; instead, it's done by many in the best case scenario. So, here's what you would do. First, you would ask your small business LOB to play more of a leadership role in ensuring the accuracy of their small business data, as that is a best practice in similarly situated financial institutions. You could also talk with the home mortgage group and have them extract their data, scrub it, and then import it into your CRA proprietary database. You can also inspire your commercial lenders to identify community development loans at origination, so that you spend less time mining for them at the back end.You can meet with marketing and inspire them to identify community development, volunteer activities upfront, so that you're always ahead of the curve. You can set a goal for your investments and treasury divisions to identify some community development investments as part of their portfolio, and then they can report that activity to you. We know that there's always such pressure on the finite resources within our banks. If you have to be an officer of one, a CRA program of one, I'd inspire you to take baby steps, to start inspiring executive management, to get your lines of businesses together in order to support your CRA program. For every dollar your bank makes, there is a commensurate cost of compliance. So, you have to build your case and slowly you can move the mark and ask for more help. Now you have to be mindful of their resource constraints as well, right? That's why it takes a while to really get the support that you need from your lines of businesses. So build a case, get executive management involved and try to lead your program with more support from the lines of businesses. CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
We spent the last few CRA tips talking about community development finance. Today's episode focuses on filling the gap when a seemingly undoable deal is before you. Our commercial lenders were trained to manage risk for the bank and to manage that risk based on various regulations, including the safety and soundness provisions. When a community development project is not quite doable, it may be up to you to recommend a path forward. Sometimes our commercial lenders haven't had the range of experiences you have and may not know what loan enhancements might be available to them. This is where your role as a CRA professional comes in. It's your responsibility to be involved in the community, to know who the key stakeholders are, and to understand who your go-to partners are when it comes to best serving the credit and social needs of disadvantaged communities. Here are a couple of ways you might consider approaching the financing gap by bringing flexible capital and equity sources to the table. • Participation Loans• Bank Financing-Debt-Conventional• CDFI-Debt (flexible debt)• Bonds (cheaper debt)• And more!Although these sources of capital can be powerful, many sources are obtained through a competitive application process and/or through various initiatives that take time to curate. But great things come to those who are patient, yes? These projects have the power to make significant impacts in the communities in which we serve, so they are worth the wait! Quotes• “If you partner with your commercial lenders more often or train them often, they might come to you then when you have a deal that might not be quite be bankable, but you can partner together, in community, to make it work.” (02:28-02:47)• “There are so many different ways that you can bring partnerships to the table to make the undoable deal doable.” (04:40-04:49)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
The best and most impactful community development finance projects are not done by any one bank, CDFI or community partner. The most monumental community-based projects are forged over time with strong leadership (and trust!) and the fortitude to manage the never-ending variables that are often required when driving impact into the most disadvantaged communities. This is where your internal and external partners come into play. Internal partners include executive management, commercial lenders, loan servicing, your investment/treasury division, compliance and legal, and marketing and PR. External partners include private sector businesses, nonprofit organizations, philanthropic entities, governmental agencies, commercial and private developers, and practitioners/consultants.These community development projects tend to take a couple of years and have many people and partners cycle through the deal. Oftentimes, CRA Officers play a convening role by offering to meet in a bank conference room or to coordinate virtual meetings. Your work in this regard will likely garner community development service hours for your bank as well.No matter the role you play, it is important to keep all stakeholders apprised of the project along the way. This is especially true for internal partners as equity sources and credit enhancements fall into place to make the seemingly un-doable deals, well, doable! I hope you now have a sense of all of the key players and can call upon them as you embark on your community development initiatives. Quotes• “It's very important that you keep all of your internal partners aware of the community development work you're doing, so when financing comes to play everybody is aware of the role you might play in community.” (02:38-02:53)Want to learn more about the CRA? Consider joining the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ LinksCRA Today Website: https://cratoday.com/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Once you have a good understanding of the technical aspects of the CRA and have stabilized your CRA program, now it's time to expand your reach into the community. Oftentimes, that will involve working alongside various stakeholders, who care deeply about serving lower income and disadvantaged communities. When working in community, you will likely be invited to participate in community redevelopment initiatives and, of course, financing will be part of that conversation! If you ask 10 bankers how they would define community development financing, you will likely get 10 different responses. As a general framework, community development finance involves economic growth in which people come together and make decisions to organize and pool assets and resources for the purposes of addressing unmet credit needs and opportunities. Let's take a deeper look at pooling assets and resources for addressing unmet credit needs. In a simplified capital stack, you'll see that conventional debt (otherwise known as conventional financing or bank debt) is at the foundation. If a bank can originate a deal, it will; however, you often will need to bring extra resources to the table to make the deal work. That is where you come in. Your job is to know about these various sources and work with the bank to consider partnering with a CDFI or bringing more equity sources to the table. In complex deals, sometimes there are more than 10 equity sources layered in with a CDFI enhancement (or first loss position) and conventional debt. I hope this gives you a glimpse into the world of community development finance. Remember: community development finance is deployed in partnership with community stakeholders who bring varied resources to the table to address challenges and barriers that can not be overcome by one bank or stakeholder alone.Quotes• “It's very important that you understand that the most productive and powerful community development initiatives require many people coming to the table and various levels within the capital stack to make the deal work.” (04:48-05:06)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Cities for Financial Empowerment (CFE) Fund: https://cfefund.org/The CFE Fund is a 501(c)3 nonprofit organization; our programmatic, research and policy efforts focus on designing, embedding and replicating financial empowerment initiatives within the fabric of local government.The CFE Fund's national Bank On platform supports local coalition and financial institution efforts to connect consumers to safe, affordable bank accounts: https://joinbankon.org/Bankers, learn more about the Bank On certification here: www.joinbankon.org/certify Research from the Federal Deposit Insurance Corporation shows that there are many reasons consumers lack a basic transaction account: not enough money for the minimum balance; distrust of financial institutions; high or unpredictable fees; or identification, credit or banking history problems. Many Americans are driven to use expensive alternative financial services, including check cashers, payday lenders and pawn shops that charge high fees for financial services that fail to help people get ahead. Without a checking account, families wind up paying too much for basic financial transactions and are hard pressed to build savings and assets.Quick Facts:• Close to 5% of U.S. households (approximately 12 million adults) are “unbanked,” without a checking or savings account.• Almost 11% of U.S. households (approximately 24 million adults) are underbanked, meaning they still use some fringe financial services.• Nearly 34% of unbanked and 45% of underbanked households earn less than $30,000 per year.• Nationally, 48% of Black households and 42% of Hispanic households are unbanked or underbanked, compared to less than 14% of white households.Why do basic transaction accounts matter?A basic transaction account is an important first step in establishing a mainstream banking relationship, depositing earnings securely, accessing credit and saving for the future. Unbanked and underbanked individuals lose the cost savings and stabilizing benefits such an account provides, such as:• Cost savings: The average unbanked person spends 5% of net income on unnecessary fees for alternative financial services. This can amount to $40,000 over a lifetime—a significant amount for those who can least afford it.• Asset building: Without a bank account, a family lacks the ability to save reliably or automatically, or establish a banking relationship that can lead to accessing affordable credit for opportunities like a car, small business, or home mortgage.• Public safety: Without a safe place to deposit their money, unbanked people are more likely to be victims of crime because they often carry large sums of cash with them or keep cash in their homes. Elderly, disabled or undocumented immigrants can be particularly vulnerable.• Financial stability: Research shows that being unbanked makes it harder to achieve financial goals like reducing debt and improving credit scores.David Rothstein, Senior Principal, CFE Fund: https://www.linkedin.com/in/david-rothstein-72a5516/David is a Senior Principal at the CFE Fund (https://www.linkedin.com/company/cities-for-financial-empowerment-fund/), where he leads the national Bank On initiative. Previously, he served as Director of Resource Development and Public Affairs for Neighborhood Housing Services of Greater Cleveland providing fund development and policy leadership. He also served as a research fellow for the New America Foundation in asset building and the Program Director for the Ohio CASH Coalition with Policy Matters Ohio. He has a BA in Political Science from John Carroll University and an MPA from Kent State University.Matt Hanke, Retail Strategies Manager, VP from Northwest Bank: https://www.linkedin.com/in/matthanke/Matt's years of banking experience from being a Customer Service Representative, Personal Banker, Mortgage Banker and now a member of Northwest Bank's executive team, has given him an unique perspective on fostering customer experiences that build relationships that exceed expectations.Northwest Bank (https://www.nw.bank/) is a $2.3 billion community bank that offers a full line of business, agricultural, mortgage, consumer deposit and lending products as well as wealth management and insurance services. Northwest Bank has 18 offices located throughout Iowa and Nebraska.Compass Digital Account (https://www.nw.bank/personal/checking/compass-digital-account) is Northwest Bank's Bank On Certified Product.~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Take a deep breath. There is life after a failed CRA data integrity exam. I've been through a few rough ones over the past 27 years, and every bank ends up with a stronger program as a result. While I can't promise a smooth path forward, I can offer a few quick tips to help you get to the root cause. First of all, you will want to identify the type of error that occurred: human or systemic. This will likely have been identified by the examiners, but if not, you will need to diagnose this right away, so you can start to understand which control points to focus on first. Then you will need to determine if the errors are isolated to a certain loan product or a certain line of business like small business or HMDA. Once you have determined the root cause, you will need to act fast!It's important to review the end-to-end process of accepting a loan application all the way through to origination. If you have a data integrity issue, be sure to bring together a CRA data working group to drive short- and long-term solutions. Lack of data integrity delays CRA examinations, causing costly rescrubbing efforts often with the support of outsourced and expensive consulting firms. Revisit your control points to determine your root cause and your path to remediation.Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Gather all of your data-related resources into one place.Review the data-related policies and procedures. Review the content. What is missing? Is it accurate? When was it reviewed last? Does it have a revision date? Create a regular review schedule and make sure to involve major stakeholders (loan officers, underwriters, loan booking, documentation, your chief compliance officer, etc.).Identify your small business control points within the bank. Do you have a data flow chart for all commercial loan products? Are specific business unit procedures documented? Have you reviewed them? Are they accurate? How often should they be reviewed? Create a regular review schedule with the appropriate executive-level review and acknowledgement.Simulate a data integrity examination. Report your findings and your specific recommendations to executive management.Train. Customize training for key stakeholders: branch employees, loan officers, underwriting, loan booking and documentation, compliance colleagues, management, executive management and the board.Train again. This best practice will never end... but the impact, critical! Quotes• “The best desktop procedures are used to help create bench strength, to help train various team members and make sure that you ensure data integrity and that it's institutionalized for your CRA program and your bank.” (02:21-02:38)• “Training of course is so key to all of this data integrity best practice.” (03:45-03:50)• “The best practices that are associated with CRA data integrity: it's never-ending, right? We have to keep working it, make sure it's part of your core governance, revisit this work and make sure you're able to ensure compliance and integrity.” (04:23-04:38)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
I'll bet you didn't guess this one! The secret to a smooth CRA data integrity exam is...your loan operations team. Yep, loan ops! Wait, what? These team members are masterful at detail with their checklists, loan code sheets, document indexing system and digitalization platforms. They are your first call when you get your sampled lists from your examiners, and they carry the heavy burden of pulling files and reading them for examiner review. They are often juggling their daily loan origination workflow and supporting various departments with one audit after another. I spend extra time taking care of these valuable team members. Make sure that you develop relationships with them in between exam cycles and recognize their efforts to ensure data integrity through the normal course of business. Most importantly, be sure to keep them in the loop as valued partners to your CRA program. The moment you receive your exam notice, inform them of key dates and what will be expected of them so they can prepare. They will need to shift priorities to pull loan files for you under the CRA program but also for your bank's compliance exam, so they are working under great pressure in the midst of their regular process flow and transactional deadlines. Once the data integrity exam is complete, loop back to them to share the outcome of the review and commend them for a job well done. You may even want to surprise them with some coffee and donuts! Quotes• “[Your loan operations officers] are always critical to your work, and god forbid you actually have to expand your sample, they're involved, too, because it's their work that's being examined as well.” (02:35-02:48)• “[Your loan operations officers] are a key piece of the team to ensure clean data and happy examiners. So, make sure that you keep them in the loop and that they're part of your CRA team, your inner circle if you will.” (02:58-03:14)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
As you know, before each exam, your regulators will conduct a review of your lending data to ensure that it is accurate enough to determine your lending performance. The regulators have a very specific approach that is delineated within the Consumer Compliance Handbook. If you haven't downloaded this yet, I would encourage you to do so today. Here is the link and notation on where to find the specific framework within the several hundred page document. Consumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf Use this as a guide for any size bank; regardless of regulator, these sampling procedures are universal. I suggest that you mimic this sampled approach on a periodic basis for your small business loans, small farm and HMDA loans. You can even use this same statistically sound approach to sample your community development loans, services and investments. The CRA sampling model employs a 5.0 percent precision level with a minimum 90.0 percent confidence. It's prudent to have an independent review embedded into your CRA program to ensure data integrity! Happy sampling!Quotes• “[An independent review] means that whoever's collecting this information, we should have someone else sampling and double checking.” (02:55-03:04)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
The purpose of CRA data collection and maintenance is to enable examiners and the public to evaluate (through issuance of a CRA Performance Evaluation) whether a bank is helping to meet the credit needs of its communities through its small business and small farm loans. Accurate data leads to accurate assessments of fair lending and CRA lending performance. When data errors do occur, not only is the bank subject to reputational risk, but costly remediations and an erosion of consumer confidence may also ensue.Three Common Challenges: • Determining which commercial loan transactions are reportable and/or which ones are not reportable (based on Call Report Schedule RC-C etc.) and then capturing reportable loans data fields accurately.• Correctly identifying community development loans.• Correctly identifying loan types based on size and definition tests.If you are new to the CRA or to data integrity elements of the CRA, start with a review of the call report Schedule RC-C instructions to learn about the common loan definitions that are consistent with the CRA and the FFIEC guide to CRA Data Collection and Reporting. Yes, I know this is a dated publication, but it is still relevant, compliant and a good guide to answer your questions regarding CRA data elements. Quotes• “Make sure that you map out how you extract data through your core systems into your CRA proprietary database that then goes to your loan register. So, you need to look end to end to make sure that you have data integrity.” (03:12-03:29)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinks• A Guide to CRA Data Collection and Reporting: https://www.ffiec.gov/cra/guide.htm • Call Report Instructions: https://www.fdic.gov/regulations/resources/call/crinst-051/2017/2017-03-051-rc-c2.pdf • CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Are you looking for creative ways to reinvigorate your CRA committee meetings?It is crucial to foster communication and collaboration during these meetings, so people leave inspired and are motivated to get involved in your CRA program. But, this is easier said than done. Here are a couple strategies that help generate a larger impact during your CRA committee meetings.• Invite a CDFI to present (either a CDFI that you partner with or that you may partner with) to learn more about their impactful work.• Bring in a nonprofit that serves low to moderate income people to educate your committee and your stakeholders on where all of the great work is happening out in your community.• Bring in philanthropic or governmental entities that are supporting economic development or serving low to moderate income people through their charters and their initiatives.• Highlight internal guest speakers, such as a board member that serves on a board of a nonprofit that serves lower income people.• Feature a “Mission Minute” where you highlight some of the great work that you've seen through your community outreach.• Create an Impact Award Program, where you highlight employees' community outreach efforts.Use your CRA committee as a think tank to create new programs, like the Bank On Program.We hope these ideas spark new interest and inspire new thoughts around your CRA program through your CRA committee.Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
When it comes to CRA program governance, there are three documents that every CRA program should have: a CRA policy, a CRA program plan and a CRA self-assessment.The CRA Policy: This document explains what you stand for, how you run your CRA program from the highest level, and how the program fits into your overall governance.The CRA Program Plan: This document explains the nitty gritty of your CRA program and institutionalizes it for the bank and your future CRA officers. What staffing do you have in place? Do you have a CRA committee? Do you collect, maintain and/or report your data? How do you actually go about analyzing your lending performance? These are all questions that the CRA Program Plan should address.The CRA Self-Assessment: This document outlines what you have accomplished; it essentially mirrors the performance evaluation.Once you get these three documents created, you can begin to take things to the next level! Quotes• “Make sure you create a CRA policy: what we stand for. Make sure you have a CRA program: what is it that we do or will do? [And make sure you have] a self-assessment: what have we accomplished?....And that all leads up to your CRA exam eventually.” (03:25-03:48)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Once you have a solid self-assessment document, now it is time to socialize it. Not only will you increase awareness of your CRA program, but you will also be using it as a training tool. Make sure you break it down to the discrete applicable parts to avoid overwhelm. Consider setting up time with the following teams...and bring coffee! Emphasize their specific impact in the work and highlight your bank's strengths and weaknesses. Listen to their responses and add their feedback as valuable performance context! • The CRA Team – your MVPs! • Bank Directors, Executive Management• CRA Committee Members• Treasury Department, Accounting as applicable• Marketing, Social Responsibility, and Foundation Officers• Retail Business Units, Commercial Lending Units Quotes• “Use [the self-assessment] document. That will position you for exam success, and you really want to socialize it, so people understand your CRA program and their role in it.” (01:39-01:51)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Does a blank page make you nervous? Yes, us too. Here are some documents you may want to reference (and even borrow the framework of!) to get you started on your CRA self assessment. • Peer Data: Download performance evaluations from similarly situated banks in your assessment areas.• Industry Data: Data from local community development think tanks, government agencies, or nonprofits. National statistics on demographics, labor, market, housing, small business, affordability, poverty, etc.• PE Templates: Performance evaluation templates are available at FFIEC.gov. Make sure to select the correct template based on your asset size (Small Institutions, Intermediate Small Institutions, Large Retail Institutions, Limited Purpose and Wholesale Institutions, and Institutions with Strategic Plans).• Standard Examiner Tables (from your previous exam): Re-create examination lending performance tables similar to what is presented within your last performance evaluation. • CRA Examination Procedures: Examination procedures are available at FFIEC.gov. Make sure you select the correct template base on your specific regulator (FRB, FDIC, or OCC).Quotes• “It's crucial to populate that blank page and just get started because a self assessment is a key practice to positioning your bank for success and backing into your desired CRA rating.” (03:35-03:51)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
There just aren't enough hours in the day. We get it. Many institutions believe they don't have time to perform a self-assessment. What you may not know is that there are many types of self-assessments, some easier than others. Check out this list of assessment types to determine what kind of assessment will best fit your institution's needs. Having a CRA self assessment is a best practice and a must have. Lite Self Assessment If you don't have one, start with a “lite” version. This is often similar to an executive summary. Take a macro-view of your entire CRA program.• Highlight key performance elements• Highlight key programsTargeted Self AssessmentDo you have a performance gap or two? Consider a targeted or micro-view of a specific performance issue and share your CRA story.• Prepare performance tables and analytics• Provide performance context• Provide bank response and proactive measuresComprehensive Self Assessment Do you already have a CRA self assessment but have't dusted it off in a while? Blend macro and micro elements to compile a comprehensive, exam-like review of your CRA program. Mirror the public evaluation framework, but cut out the fluff.• Showcase your performance• Provide performance context to address gaps and highlight bank response• Highlight bank-wide initiatives• Weave in your CRA storyQuotes• “Self assessments are the way for you to demonstrate what you feel the final outcome might be for the exam.” (02:41-02:48)• “I like to go in there saying, ‘We have an excellent CRA program, and here's the document that will show you why we believe that to be true.'” (06:32-06:42)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Many banks make the mistake of spending too much time over-analyzing their performance history without giving equal airtime to formulating new strategies to address performance gaps within their CRA programs. It is imperative to create a self assessment that mimics a regulatory framework to assess your past performance. This document will not only get you exam-ready, but it will also serve as a foundation to build upon. Once you have a solid understanding of your bank's key performance indicators, you can then move forward in developing strategies and partnerships with community-based initiatives and organizations to proactively address your performance gaps. Make sure your CRA plans include internal and external stakeholders and span over a calendar year as well as over your next examination multi-year scope.Quotes• “So don't forget to look back and have your comprehensive self-assessment document, but also don't forget to look forward and forge community-based partnerships to effectuate community development change.” (03:20-03:33)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm
Do you know what your bank's strategy is? If this is not something that has been shared with you, reach out to leaders within your organization's hierarchy to learn more. Ask questions like, “What are your division's key priorities?” and/or “What is the major initiative you are focusing on this year?” Take this information and brainstorm ways that you can align their strategies and initiatives with your CRA program priorities. Aligning your CRA strategy with your institution's overall strategy will make it easier for employees to see how their role adds value to the bank's core business, while also contributing to the bank's CRA goals.This is an iterative process and won't happen overnight, so be patient. Take baby steps to move your CRA program into alignment with your institution's overall strategy and mission. In time, your CRA strategies will be seen as mission critical and in lockstep with the bank's bottom line. Quotes• “You want to make sure that you are seen as a key role, a key player in the overall bank strategy while you lead your CRA program. Take a moment to think strategically about how you can align your CRA programs with the core initiatives of the bank.” (03:22-3:38)Want to learn more about the CRA? Sign up for CRA Today's free course: https://hub.cratoday.com/freecourseLinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.
The single most important CRA exam prep tool for you to consider is a CRA self-assessment. CRA self-assessments are assessments you perform on your own institution to understand your CRA strengths and performance gaps. If done correctly, the self-assessment mirrors an examiner's approach to assessing your performance under the CRA. This assessment helps you understand how you're currently performing, so you can prepare your performance context and story for your next CRA examination. There are three different types of CRA self-assessments: lite, targeted and comprehensive.Self-assessments are living and breathing documents that should be refreshed throughout the year. The length of the period depends on your institution's situation/size. Self-assessments are an industry best practice and are the number one tool that has a tangible return on investment for your CRA program and your next CRA exam. No one knows your bank better than you; you should control the narrative. Don't leave this up for the examiners to decide! They don't have the time and they are not as invested as you are in the communities you serve. Quotes• “The best part of the CRA self-assessment is where you get to delineate and share your CRA story. This is the most powerful part of this document. You set the tone for your performance, your gaps, your mitigants and how you are proactively serving your community.” (2:09-2:28)• “I know you're doing the good work, so maximize the story with a CRA self-assessment.” (4:37-4:44)LinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing: https://meetfireside.com/podcast-production-service/
Community Development Financial Institutions (CDFIs) were created to deliver responsible, affordable lending to help low-income, low-wealth and other disadvantaged people and communities join the economic mainstream. CDFIs can't do this work alone. They are your partners in community development, not your competition! CDFIs make loans that you can't make due to regulatory constraints, which makes them excellent partners. Reach out to your local CDFI and consider the vast array of partnership opportunities, including:• Instituting a loan referral program (formal or informal arrangements)• Serving on a loan approval or fundraising committee• Helping CDFIs refine their loan underwriting policies and procedures• Developing secondary market vehicles or programs• Assisting in marketing financial services, including the development of advertising and promotions• Co-collaborating on publications, workshops and conferences• Assisting a CDFI in securing a new loan origination system• Providing loan servicing for free or a reduced rate • Providing merchant services or other banking services• Partnering on a New Markets Tax Credit ProjectQuotes• “Community Development Financial Institutions or CDFIs are well-positioned to aid in COVID recovery in partnership with banks. There are so many different ways that banks can partner with CDFIs to do innovative work and to deploy capital in disadvantaged communities.” (1:12-1:32)• “[Referrals] are a very, very key way that you can partner with a CDFI to the extent that you can't extend a loan to a small business, for example, but with proper permission can refer it to a CDFI. You get to keep the deposits and the relationship, then hopefully the CDFI will serve the small business by building their acumen and financial skills and then allowing them to access credit, so that eventually they'll come back to the bank when they are bankable.” (2:09-2:43)LinksCDFI Fund: https://www.cdfifund.gov/Opportunity Finance Network: https://ofn.org/CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing: https://meetfireside.com/podcast-production-service/
Join the network of thousands of volunteers that ensures millions of low-income taxpayers receive billions of dollars in refunds, a network that helps the community meet their civic obligations as taxpayers and supports them on the path to financial security and opportunity. Consider volunteering for the Volunteer Income Tax Assistance (VITA) program. You can volunteer in your local community through various VITA sites, usually run by local nonprofit organizations (Goodwill, YMCA, Catholic Charities, etc.). You can potentially get CRA service consideration for both the training and the actual tax preparation services you perform through the program.Also, don't fret – you don't have to be a tax wiz to do this! You'll learn everything you need to know through the VITA training program.Quotes• “Did you know that there's $2.2 billion at stake for low-income taxpayers? Now, why am I talking about taxes and it's August? Well, this is really the perfect time for you to get involved and to get trained, so that you can support the VITA program in your community.” (1:09-1:29)• “[This program] utilizes volunteers like bankers, and you get trained on an online portal, and you sit down with taxpayers, and you help them complete their taxes. And then they're subject and well-positioned to get the refunds that they are then eligible for.” (1:49-2:06)Links• VITA: https://www.irs.gov/individuals/free-tax-return-preparation-for-qualifying-taxpayersThe IRS's Volunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE) programs offer free basic tax return preparation to qualified individuals.• IRS Tax Volunteers https://www.irs.gov/individuals/irs-tax-volunteers• CRA Today Website: https://cratoday.com/ • For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing: meetfireside.com/podcast-production-service/
According to Experian data, if you have a credit card or two in your wallet, you're not alone. There is over $756 billion in outstanding credit card debt in the U.S., and approximately 95% of adults have a credit card account open in their name, according to Experian data from the third quarter (Q3) of 2020.In other words, every month should be financial literacy month! You don't have to wait for next April to come to deploy financial literacy programs. The best time is now! There are many ways to adopt and/or develop a financial literacy curriculum. You can use the ABA's curriculum, partner with a CDFI/nonprofit, or develop/adopt your own curriculum. You can more easily develop your own curriculum using a service such as Everfi.Quotes• “Did you know that the average American has $90,000 in consumer debt?” (1:09-1:14)• “There are many different options for you to choose from. Do it alone or do it with someone else – either way, we need to all band together and help raise the next generation of financial literate families.” (2:23-2:38)Links• ABA Financial Education Program: https://www.aba.com/about-us/aba-foundation/financial-education-programs#• EVERFI: https://everfi.com/financial-education/• Banzai: https://teachbanzai.com/• FDIC Money Smart: https://www.fdic.gov/resources/consumers/money-smart/index.html• CRA Today Website: https://cratoday.com/ • For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing: https://meetfireside.com/podcast-production-service/
The low-hanging fruit of community development services is…boards and committees! Many bank executives and employees are or could be serving on nonprofit boards and committees. These service hours and activities count towards the majority of community development services for most banks. Make sure you are diligently collecting this data and not letting it fall through the cracks. You may want to add a link to your intranet or launch a campaign and incentivize employees to report their board and committee service hours. Quotes• “I estimate that the boards and committees that your bankers serve on probably equates to 70-80% of the total volume of your community development services.” (1:35-1:49)• “I want you to reach back out on a periodic basis to try to gather those community development services on behalf of your bankers, your employees, your executives. Oftentimes, we underreport because we're just not getting the information.” (2:28-2:48)• “There's a lot of volume of community development services through regular bank volunteerism.” (3:34-3:40)LinksFor an easy way to collect volunteer hours and data, visit this link: https://www.kadince.com/community-involvement-software/volunteer-service-tracking CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing: https://meetfireside.com/podcast-production-service/
Can the countless hours you've spent on the SBA Paycheck Protection Program (PPP) count as a community development service?The answer is yes and no! Although your bank worked seemingly around the clock last year to stand up the SBA PPP, none of the hours spent internally creating the loan application portals, working on underwriting and compliance or deploying loans under the program count towards your CRA program.You will, however, count the SBA PPP as a special loan program and loans will count either as small business loans or may qualify as community development loans depending on the circumstances.Quotes• “You do get credit for offering the program in general….You get a credit as a special loan program, but not the actual hours associated with ‘volunteering,' because it wasn't really a volunteer activity.” (1:58-2:18)• “So, the community development loans must have a community development purpose, but there are ways to get lending credit for it.” (2:49-2:55)LinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Enrollment opens July 26-30, 2021.Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing: https://meetfireside.com/podcast-production-service/
On this week's CRA Tip episode, we explore three community development services you might be surprised don't count as CRA activities. Here is a brief overview:1. Serving food at your local homeless shelter. This activity does not relate to the provision of financial services.2. Helping build a Habitat for Humanity home during a weekend build. Again, this activity does not relate to the provision of financial services. 3. Ringing the bell for the Salvation Army's major fundraiser each holiday season that raises over $125 million to support hunger alleviation and poverty reduction for our most vulnerable. Even though you are technically “fundraising,” which is now allowed per the 2016 Q&A, I have yet to find a bank that has received favorable CRA consideration for this activity.
Take a second look at the retail distribution of your branches, ATMs and deposit-taking ATMs. Sometimes, it is helpful to map these data points to visualize how far away your branches and ATMs are from the next closest low- or moderate-income area. Now that you're looking more closely, does your retail distribution arbitrarily exclude LMI geographies?Make sure to work closely with the executive management, compliance and legal departments to ensure that any changes to branching strategy (opening, consolidating and closing branches) are vetted from a CRA perspective. In addition, make sure that your bank's policies and procedures reflect the same.Quotes• “That is the art of CRA: making sure that you embed a CRA conversation into some of the key strategies at your bank.” (2:18-2:26)LinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Enrollment opens July 26-30, 2021.Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing: https://meetfireside.com/podcast-production-service/
Last week, we talked about community development loan identification best practices – the low-hanging fruit that may already exist at your institution.Now, we switch our attention to proactive measures! Here are some best practices to increase the number of community development loan prospects that come across your desk. 1. AUTOMATE. Program your core system with community development definition prompts, so business lending units can easily identify potential community development loans at origination and onboarding.2. BUILD. Develop relationships with your loan teams through targeted training and frequent visits to stay “top of mind,” so loan officers will be more apt to alert you when a community development loan prospect presents itself.3. INSPIRE. Encourage and reinforce your loan officer's involvement in the CRA program by sharing impactful stories and community development examples from their own lending portfolios.Quotes• “You can also work out in the community and even have a community development prospect of your own through your community development work and bring it to your commercial loan officers, so it can be a two-way street.” (2:45-2:59)• “You can come back to [your loan officer] and say, ‘You know that loan you made to this non-profit organization? Let me tell you a little bit more.' And you can talk about the impact that their loan made in changing lives.” (3:14-3:28)LinksCRA Today Website: https://cratoday.com/ Register for our upcoming Community Development Loan Workshop: www.cratoday.com/workshopTo sign up for our free course: https://hub.cratoday.com/freecourseFor more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing
You can't do this work alone. In fact, the best CRA programs are built around key stakeholders working together towards the same CRA goals. As you know, mining for community development loans (CDL) can be a very manual and time-consuming process. This is especially true given that the subjective and technical definitions of a CDL aren't often necessary within each credit approval memorandum write-up. So, who is key to this work? 1. Key business lending units are the pathway for solid leads and early identification. Depending on the size of your bank, key departments and divisions might be small business banking, commercial lending, corporate banking, commercial real estate division, or many iterations of the same. No matter what your bank calls each lending area, the secret is forming alliances with these departments and their key team members. 2. Even the marketing department might have some insight. Most marketing departments have built relationships with nonprofit organizations through service initiatives and grant making. Sometimes these nonprofits also have banking or credit needs that might just count as community development loans in the end. LinksCRA Today Website: https://cratoday.com/ Register for our upcoming Community Development Loan Workshop: www.cratoday.com/workshopTo sign up for our free course: https://hub.cratoday.com/freecourseFor more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing
Regulators are currently revisiting the way they define a community development loan (CDL) through CRA modernization efforts. So until there is more regulatory certainty, how do you determine how many CDL qualified loans are enough? While you can't guarantee anything during the iterative swirl of CRA reform, this episode aims to give you a good idea of reasonable targets when executive management asks “how much is enough.” Here's where you should start:• Look at your performance year-over-year to benchmark against your own performance. Specifically, review the following: (1) Year-over-year community development loan volume (# and $ amount) in each assessment area and/or rolled up overall. (2) CDLs as a percentage of total loans and total assets. This will help you compare your CDLs against your loans and assets growth. • Benchmark yourself against similarly situated competitors. To do this, download your competitors' performance evaluations and disclosure statements. Do this for 2-3 similarly situated banks. Quotes• “As you know, we're in the middle of regulatory change, and while some of the core concepts are being revisited, it's very important to know where you stand today: how much is enough?” (1:22-1:33)• “You can benchmark yourself against similarly situated organizations, similarly situated banks. You can actually download their performance evaluations, and even though it'll be a little bit dated, you know that we don't have huge swings year over year. So, we can make some general and sound conclusions about their performance to then look at our performance in context.” (2:35-3:03)LinksCRA Today Website: https://cratoday.com/ To join the waitlist for our upcoming Community Development Loan Workshop: www.cratoday.com/waitlistTo sign up for our free course: https://hub.cratoday.com/freecourseFor more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing: https://meetfireside.com/podcast-production-service/
When looking through your loan portfolio for qualified community development loans, it is essential to have a strategic approach given limited time and resources to conduct a 100% review. A tactical approach can save you time and help you qualify more loans to support your bank's lending performance.Start with these subsets of community development loan prospects to yield an efficient review:• Loans to nonprofit organizations of any dollar amount• Small Business Administration (SBA) 504 loans• Renewals and major modifications• Loan officer/system identified loans• LMI areas/redevelopment districtsStart with the largest loans and work your way down the list. Remember to pull data on business loans over $1 million, because loans for less than $1 million are generally small business loans (including PPP loans). Quotes• “When we can't do a 100% review...you can take a tactical approach, and this will save you time and, if done methodically, you can actually increase your portfolio of community development loans. You can enhance your bank's lending performance.” (1:37-1:57)• “Start with a subset of all of the loans that you've originated for a commercial purpose. And then you can create subsets and then pull down different segments of those loans to be strategic with your review.” (1:58-2:12)LinksCRA Today Website: https://cratoday.com/ To join the waitlist for our upcoming Community Development Loan Workshop: www.cratoday.com/waitlistTo sign up for our free course: https://hub.cratoday.com/freecourseFor more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by FIRESIDE Marketing: https://meetfireside.com/podcast-production-service/.