Follow The CRA Podcast

The CRA Podcast

The CRA Podcast was created to elevate Community Reinvestment Act (CRA) concepts and inspire industry leaders to consider new approaches to their economic and community development reinvestment pursuits.

Join me for these lively and deeper conversations with today’s community development leaders as they embark upon innovative collaborations.

CRA Podcast Episodes

CRA Podcast Episodes

Sarah Hope Marshall joins me here to reflect upon digital inequity in place-based community revitalization. Our discussion focuses on digital inequity and how community development professionals can revisit this as they revisit their community development programs. Here are some key quotes from our conversation:
CRA TODAY
SHOWNOTES: Episode 76: Beyond Bricks and Mortar: Rethinking Community Development Strategy to Address Digital Inequity with Sarah Hope Marshall

Sarah Hope Marshall joins me here to reflect upon digital inequity in place-based community revitalization. Our discussion focuses on digital inequity and how community development professionals can revisit this as they revisit their community development programs. Here are some key quotes from our conversation:

“It made me pause and ask, wait a minute. This neighborhood that we’re in has a really rich history of community organizing and groups working together. There’s been books written about it. In my research, I’d done work studying the first-ever tenant buyout of a HUD affordable building that was turned into co-ops in this neighborhood I was working in. And so, I started asking the question, What happens when technology allows people to be more mobile, to be less attached to the community in the place they’re in?”

“If you think about the trajectory of where we are, CRA and the CDFI fund and the way that was initiated really came about because of place-based community organizing. And now, we’ve come to a place where technology has really expanded our social networks so that we’re constantly communicating with people all over the country.”

“It’s a different dynamic, and we adopt things slowly, so we don’t always pause to say, wait. How has my world changed because of technology?”

“I’ve been excited to see things that have developed and researchers who are working on things like tech ethics, digital equity, and the digital divide, but there’s still just a lot that’s unknown in terms of how technology’s really impacting our socioeconomic mobility and the choices that we have.”

“There’s an initiative called the National Collaborative for Digital Equity that has started a campaign called One Percent for Digital Equity, and the call is to ask CRA officers to commit one percent of their CRA budget to digital equity. It’s opened up a really powerful funding stream for organizations who are trying to do this work.”

“Digital equity really doesn’t have to be a new project, program, or strategic plan, but an overlay. Because if we think about the way technology really overlays everything we do and how we function as a society and our roles, it’s just a matter of pausing to ask those questions and encouraging the people that we interact and work with to ask those hard questions so that we’re achieving the goals that we set out to achieve.”

Contact Info for Sarah:
Sarah Hope Marshall
1-773-595-0974
sarahhope@profoundhopeindustries.com
subdomain.profoundhopeindustries.com/digital-equity

Article: Reckoning with Digital Inequity in Place-Based Community Revitalization:
https://www.jpna.org/index.php/jpna/article/view/873

1% for Digital Equity Campaign: https://www.digitalequity.us/1-for-digital-equity/

Article Abstract:
Place-based community development in America has a rich history. Practices and procedures for successful redevelopment are supported by lobbying efforts, public administration, policy, federal funding, and the efforts of non-profits dedicated to neighborhood revitalization. Community revitalization work is often centered around specific geographic locations, while in recent decades modern technology has caused social networks to become increasingly geographically disparate. Social networks have been demonstrated to support the economic mobility that community development strives to create. However, the impact of modern technology on place-based community development has not been clearly understood. Increasing digitalization has impacted the effectiveness of place-based social equity efforts such as community organizing, affordable housing and economic development, and financial capability interventions. This essay explores how place-based community organizing led to the creation of current policies that govern community development, how technology has impacted urban communities and how these changes may subsequently affect social equity objectives in public administration.

CRA Today Website: https://cratoday.com/

CRA Hub: https://cratoday.com/hub

Linda 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 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.
CRA TODAY
SHOWNOTES: Episode 64: Bridging the Racial Wealth Divide with NCRC's Community Development Fund

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 Experience

Marisa 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/hub

Linda 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.

Joshua shares his work as the bank’s Fair Banking Officer, including CRA, Fair Lending, HMDA, 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!

CRA TODAY
SHOWNOTES: Episode 63: CDFI Partnership with Joshua Kummer

Joshua shares his work as the bank’s Fair Banking Officer, including CRA, Fair Lending, HMDA, 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

Are 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.

CRA TODAY
SHOWNOTES: Epsiode 61: Community Development Loans Demystified with Krista Shonk, VP & Senior Counsel, Regulatory Compliance and Policy, Fair & Responsible Banking, ABA

Are 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.

“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.

CRA TODAY
SHOWNOTES: Episode 54: Inspiring Our Next Generation of Financially Literate Students with Abby Coyle, CEO and Co-Founder, ClassEquity

“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 page

Contact info: abby@classequity.com

For 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

This episode interviews David Rothstein, Senior Principal, CFE Fund and Matt Hanke, Retail Strategies Manager, VP from Northwest Bank as they share the impact and promise of the Bank On program where they are working to bring the unbanked and the underbanked into the financial mainsteam. 

CRA TODAY
SHOWNOTES: Episode 38: Bank On: Bringing the Unbanked and Underbanked into the Financial Mainstream

This episode interviews the following leaders in community development:

  • David Rothstein, Senior Principal, CFE Fund
  • Matt Hanke, Retail Strategies Manager, VP of Northwest Bank

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 bevictims 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.

    Questions?  Reach out to us at info@cratoday.com

    This episode interviews Lynette Bell, President of the Truist Foundation, Armeer Kenchen, Executive Director of CornerSquare Community Capital, “HP” Harold Pettigrew, CEO of Wacif and Jerrell “J” Deaver, Board Member and Investment Committee Chair of Natural Capital Investment Fund.  The podcast highlights the power of bank and CDFI partnerships in serving racially and ethnically diverse small business owners, women, and individuals in low- and moderate-income communities.

    CRA TODAY
    SHOWNOTES: Episode 11: The Catalytic Impact of a $40 Million Investment in the CDFI Sector

    This episode interviews the following leaders in community development:

    • Lynette Bell, President of the Truist Foundation
    • Armeer Kenchen, Executive Director CornerSquare Community Capital and the NC Rural Center’s State Small Business Credit Initiatives
    • Harold Pettigrew, CEO Wacif
    • Jerrell “J” Deaver, “retired” banker from First Citizens Bank, Board Member and Investment Committee Chair Natural Capital Investment Fund

    BB&T and SunTrust formed Truist with a shared purpose – to inspire and build better lives and communities equally and equitably across all geographies. By providing grants in support of nonprofit organizations through the Truist Foundation, we can help grow their impact. In the first half of this episode, we will hear from Lynette Bell, President of the Truist Foundation. Learn more about why Truist decided to invest $40 million in the CDFI sector and how banks, both large and small, should go about approaching CDFIs in their respective markets.

    In the second half of this episode, we will hear from three members of the new CornerSquare Community Capital Team – Armeer Kenchen (Executive Director CornerSquare Community Capital and the NC Rural Center’s State Small Business Credit Initiatives), Jerrell “J” Deaver (Board Member and Investment Committee Chair Natural Capital Investment Fund), and Harold Pettigrew (CEO Wacif). Launched by the NC Rural Center and Truist, CornerSquare emerged from the BB&T and SunTrust merger and is a new resource for the CDFI sector. Through this innovative program, one hundred percent of funding will be allocated to racially and ethnically diverse small business owners, women, and individuals in low- and moderate-income communities, with a focus on Black-owned small businesses.

    Modeled after the NC Rural Center’s Loan Participation Program, CornerSquare Community Capital will be a long-term, sustainable solution to support CDFIs working with small businesses at the local level. By purchasing a portion of loans made by a CDFI to historically underserved entrepreneurs, CornerSquare will enable the participating CDFIs to increase their lending capacity with their existing capital, ultimately expanding their reach and support to more small businesses in their operating areas. It will also enable CDFIs to lower transaction risk through the program’s subordinate position, allowing participating lenders to support high mission projects that otherwise might not have fit their credit criteria.

    CornerSquare Community Capital will initially focus on CDFIs located in Truist’s footprint, which includes the following states: North Carolina, South Carolina, Virginia, Maryland, West Virginia, Kentucky, Tennessee, Georgia, Florida, Alabama, Indiana, Texas, New Jersey, Ohio, Pennsylvania, Arkansas, Mississippi, and Washington, D.C.

    There are currently five CDFI partners in the program: ACE,NCIFund, Pathway Lending, Wacif, and BBIF. CornerSquare Community Capital is accepting additional CDFIs, as well as Minority Depository Institutions (MDIs) into the program. Interested organizations should contact Julia Malinowski, Director of Strategic Initiatives at jmalinowski@cornersquare.org. CornerSquare will operate as a subsidiary of the NC Rural Center, a nonprofit that has worked for more than 30 years to support small business owners and entrepreneurs in low- and moderate-income communities. For general inquiries, contact info@cornersquare.org.

    The Washington Area Community Investment Fund’s (Wacif) mission is to promote equity and economic opportunity in underserved neighborhoods in the Washington, D.C. region. Their mission is driven by three strategic pillars: inclusive entrepreneurship, community wealth building, and equitable economic development, and is fulfilled by providing access to capital products and services, and capacity building technical assistance to low- and moderate-income entrepreneurs.

    The Natural Capital Investment Fund (NCIFund) specializes in triple-bottom-line enterprises—those that address the “3 E’s”:

    • Economy: Generates a viable financial return, either by maintaining or creating profits, return on investment, or a tangible asset.
    • Equity: Provides an opportunity for disadvantaged groups to access information, financial resources, vital community services, or livelihoods/employment.
    • Ecology: Benefits or lessens impact on the natural world by improving stewardship of natural resources, or reducing energy use, waste, pollution, or materials use.

    For general inquiries about Natural Capital Investment Fund, contact Marten Jenkins at mjenkins@conservationfund.org or 681-252-4276.

    CRA Today and the CRA Hub

    Linda Ezuka, Founder, CRA Today and the CRA Hub

    www.cratoday.com

    www.cratoday.com/hub

    The CRA Hub is a new way to connect and forge community development impact through our CRA programs. The CRA Hub is an exclusive membership for bank professionals to connect with fellow colleagues, find inspiration and master the art of the CRA.

    No matter where you are on your CRA journey, the CRA Hub has something for you. This membership is for you if:

    • you are new to CRA due to a promotion, new job or position or were never formally trained on CRA;
    • you understand key CRA program elements and have navigated through your first CRA exam cycle and want to deepen your understanding of CRA best practices;
    • you are making progress on the integrity of your bank’s CRA data collection, maintenance and/or reporting and want to ensure enhanced data integrity;
    • you want to learn from experts about refreshing your CRA programs, and discover innovative programs to consider in your assessment areas;
    • you are navigating CRA regulatory reform or you suspect reform is on the horizon;
    • you want to vet an idea and discuss your approach to CRA decisions with CRA colleagues who understand the unique challenges in your programs; or
    • you want to forge potential partnerships for impact in a broader regional area.

    Questions?  Reach out to us at info@cratoday.com

    This episode interviews Brett Simmons, Fund Manager, and Joyce Klein, Chair of the Board of the EBA Fund and Director of Business Ownership Initiative, a program of the Aspen Institute. The podcast highlights the launch of Entrepreneur Backed Assets (EBA) Fund.

    CRA TODAY
    SHOWNOTES: Episode 10: EBA Fund: Converting the promise of entrepreneurship into assets that build economic inclusion and equity

    CRA Podcast Episode: EBA Fund: Converting the promise of entrepreneurship into assets that build economic inclusion and equity

    This episode interviews Brett Simmons, Fund Manager, and Joyce Klein, Chair of the Board of the EBA Fund and Director of Business Ownership Initiative, a program of the Aspen Institute.  The podcast highlights the launch of Entrepreneur Backed Assets (EBA) Fund, is a new nonprofit creating a secondary market for microloans, a new tool to help capitalize CDFI lenders doing amazing work to serve entrepreneurs of color, small businesses in low-income communities, and the millions navigating through the pandemic. 

    The EBA Fund has been made possible thanks to the Citi Foundation, the Bill & Melinda Gates Foundation, the Robert Wood Johnson Foundation, Microsoft Corporation, and Woodforest National.

    More information can be found at ebafund.org and at https://lnkd.in/g65muHd

    Link to EBA Fund Presentation

    Microenterprise Primer and Information: https://www.aspeninstitute.org/topics/microenterprise/

    Brett Simmons, Fund Manager, EBA Fund

    brett@ebafund.org

    Brett Simmons is the Managing Director and Principal with Revolve and leads fund management for EBA Fund. He has more than a decade of program, planning, and entrepreneurial experience across industries. As Director of Programs and Policy, he was instrumental in Accion Chicago’s efforts to expand lending more than 150% during the aftermath of the financial crisis. Since that time, he has worked with several start-up engineered systems companies and in operations strategy and planning for Cummins Power Systems, a fortune 200 manufacturing firm. Brett earned a joint B.A. in Economics and History from Xavier University and has both a Master of Business Administration and Master of Philosophy of Religion from Yale University.  

    Joyce Klein, Chair of the Board, EBA Fund

    joyce.klein@aspeninstitute.org

    Joyce Klein is the director of the Business Ownership Initiative, a program of the Aspen Institute, which advances business ownership as an economic opportunity strategy. Ms. Klein assumed the leadership of BOI (formerly FIELD) in 2012, after working as a senior consultant since the program’s inception in 1998. She is recognized as a leading expert on the field, speaking at national and regional industry conferences and being quoted in a variety of news media including The New York Times and National Public Radio’s Marketplace. Joyce has more than 20 years of experience studying and supporting microenterprise and entrepreneurial development programs in the United States, and has authored or co-authored numerous publications, including funder brief and strategy guides, evaluation and research reports, case studies and policy briefs. She has also designed and managed grant programs aimed at supporting innovation in the practice of microenterprise development in the United States.

    Under Ms. Klein’s leadership FIELD launched the Microfinance Impact Collaborative, helped to create the Small Business Borrowers’ Bill of Rights and the Responsible Business Lending Coalition, and launched new research into the role of platforms and networks in expanding the scale and impact of the US microenterprise field. BOI’s work includes examining the potential role of business ownership and the microenterprise field in addressing the challenges of financial inclusion, the racial wealth gap, and career development for youth.

    Ms. Klein also has worked as a consultant in the microenterprise field, providing assistance to clients including the Community Development Financial Institutions Fund of the US Department of the Treasury, and CFED (formerly the Corporation for Enterprise Development). Prior to her work with BOI, Ms. Klein led CFED’s work in microenterprise development. She holds a master’s in public policy from the University of California at Berkeley and a B.A. in economics from Boston College.

    CRA Today and the CRA Hub

    Linda Ezuka, Founder, CRA Today and the CRA Hub

    www.cratoday.com

    https://cratoday.com/Hub 

    The CRA Hub is a new way to connect and forge community development impact through our CRA programs. The CRA Hub is an exclusive membership for bank professionals to connect with fellow colleagues, find inspiration and master the art of the CRA. 

    No matter where you are on your CRA journey, the CRA Hub has something for you. This membership is for you if: 

    • you are new to CRA due to a promotion, new job or position or were never formally trained on CRA;
    • you understand key CRA program elements and have navigated through your first CRA exam cycle and want to deepen your understanding of CRA best practices;
    • you are making progress on the integrity of your bank’s CRA data collection, maintenance and/or reporting and want to ensure enhanced data integrity;
    • you want to learn from experts about refreshing your CRA programs, and discover innovative programs to consider in your assessment areas;
    • you are navigating CRA regulatory reform or you suspect reform is on the horizon;
    • you want to vet an idea and discuss your approach to CRA decisions with CRA colleagues who understand the unique challenges in your programs; or
    • you want to forge potential partnerships for impact in a broader regional area.

    This episode interviews find CRA Co-Founders, Ben Loehle and Brian Waters, and Ted Gerbick, Director of Marketing & Philanthropic Giving and Emily Gardner, Senior CRA Analyst of First Western Trust. Together we explore tools for modern day CRA programs, regulatory reform and philanthropic priorities during the pandemic. We end on a lighter note sharing our hopes for a fresh new year putting COVID behind us and looking forward to in-person convenings and more high impact community development work.

    CRA TODAY
    SHOWNOTES: Episode 9: findCRA and First Western Trust-Partnering for Impact

    CRA Podcast Episode:  findCRA and First Western Trust-Partnering for Impact

    This episode interviews findCRA Co-Founders, Ben Loehle and Brian Waters, and Ted Gerbick, Director of Marketing & Philanthropic Giving and Emily Gardner, Senior CRA Analyst of First Western Trust. Together we explore tools for modern day CRA programs, regulatory reform and philanthropic priorities during the pandemic. We end on a lighter note sharing our hopes for a fresh new year putting COVID behind us and looking forward to in-person convenings and more high impact community development work.

    findCRA

    findCRA is a national software and CRA consulting company, supporting banks of all sizes in the smallest communities to the largest cities.  findCRA’s software is designed with a “CRA first” approach to provide powerful data, search tools and support services that help banks research and connect with CRA-qualified nonprofits and better understand their communities. Learn more at www.findCRA.com 

    Ben Loehle, CEO & Co-Founder

    Brian Waters, President & Co-Founder

    Links to findCRA’s Software Solutions:

    Community Qualifier

    Contexter

    Request a Demo

    First Western Trust

    Our mission is to be the best private bank for the Western wealth management client and our integrated business model distinguishes us from other banks and non-bank financial services companies in the markets in which we operate. We believe that the “Western wealth management client” shares our entrepreneurial spirit and values our sophisticated, high-touch wealth management services that are tailored to meet their specific needs. https://myfw.com/

    Community Involvement and Philanthropic Pillars

    https://myfw.com/community/

    Ted Gerbick, Director of Marketing & Philanthropic Giving 

    Theodore joined First Western in April of 2019 as Director of Marketing. In this role, Theodore develops and delivers First Western’s strategy and approach for marketing, advertising, public relations, communications, and philanthropic giving activities.  Theodore works directly with senior leaders across the organization to infuse everything First Western does with the promise of our brand for our clients, associates, and stakeholders.

    Previously, Theodore served in leadership roles focused on strategy, marketing, analytics, and product management for KeyBank and CoBank, headquartered in Ohio and Colorado, respectively. Theodore brings with him nearly 20 years of working knowledge related to the development and marketing of payments, commercial card, cash management, and real estate services.

    Credentials: BA, Marketing – Kent State University, MBA, Leadership and Business Management – Kent State University

    Emily Gardner, Senior CRA Analyst

    Emily joined First Western in June of 2017 and currently serves as CRA Analyst. In this role, Emily administers and oversees the daily operation of the Bank’s CRA program, maintains CRA documentation, and delivers organization-wide CRA training. Emily is also responsible for the preparation of analyses and reporting related to First Western’s CRA compliance and oversight committees.

    Additionally, Emily works closely with other members of our CRA Committee and our associates to ensure that First Western continues to reach our CRA goals each year.

    Prior to First Western, Emily successfully launched and owned a small online business, for which she was awarded Entrepreneur of the Year by the Young Americans Center for Financial Education.

    Credentials: BS, Business Administration: Marketing and Information Management – University of Colorado 

    CRA Today and the CRA Hub

    Linda Ezuka, Founder, CRA Today and the CRA Hub

    www.cratoday.com

    https://cratoday.com/Hub 

    The CRA Hub is a new way to connect and forge community development impact through our CRA programs. The CRA Hub is an exclusive membership for bank professionals to connect with fellow colleagues, find inspiration and master the art of the CRA. 

    No matter where you are on your CRA journey, the CRA Hub has something for you. This membership is for you if: 

    • you are new to CRA due to a promotion, new job or position or were never formally trained on CRA;
    • you understand key CRA program elements and have navigated through your first CRA exam cycle and want to deepen your understanding of CRA best practices;
    • you are making progress on the integrity of your bank’s CRA data collection, maintenance and/or reporting and want to ensure enhanced data integrity;
    • you want to learn from experts about refreshing your CRA programs, and discover innovative programs to consider in your assessment areas;
    • you are navigating CRA regulatory reform or you suspect reform is on the horizon;
    • you want to vet an idea and discuss your approach to CRA decisions with CRA colleagues who understand the unique challenges in your programs; or
    • you want to forge potential partnerships for impact in a broader regional area.

    In this episode of the CRA Files, Ron Brooks interviews Linda Ezuka: Consultant. Community Advocate. Committed to transforming communities through the power of economic development and CRA. Listen to hear Linda describe her vision for the CRA Hub and other community development thoughts.

    CRA TODAY
    SHOWNOTES: Episode 8: Demystifying Community Reinvestment

    In this episode of the CRA Files, Ron Brooks interviews Linda Ezuka: Consultant. Community Advocate. Committed to transforming communities through the power of economic development and CRA.  Listen to hear Linda describe her vision for the CRA Hub and other community development thoughts.

    CRA Partners is a turnkey CRA compliance program powered by the Senior Housing Crime Prevention Foundation. The Foundation operates Senior Crimestoppers, a nationwide crime prevention program educating and safeguarding against theft, abuse and neglect. Senior Crimestoppers is funded exclusively by the banking industry.

    Partner with us and you will satisfy your bank’s CRA requirements, boost your community relations profile and develop new business relationships, while ensuring safe, secure senior living environments, HUD communities and state veterans homes.

    https://shcpfoundation.org/cra-partners/

    This episode interviews Jenny Flores, who leads the Wells Fargo Foundation as their Head of Small Business Growth Philanthropy. Jenny joins me in a community development conversation and Wells Fargo’s commitment to diversity, equity and inclusion in their programs supporting small business. This episode highlights the power of diversity, equity and inclusion in our collective community development work.

    CRA TODAY
    SHOWNOTES: Episode 7: The Power of Diversity in Community Development

    This episode interviews Jenny Flores, who leads the Wells Fargo Foundation as their Head of Small Business Growth Philanthropy. Jenny joins me in a community development conversation and Wells Fargo’s commitment to diversity, equity and inclusion in their programs supporting small business.  This episode highlights the power of diversity, equity and inclusion in our collective community development work. 

    Jenny Flores, Head of Small Business Growth Philanthropy

    Jenny Flores is Head of Small Business Growth Philanthropy for the Wells Fargo Foundation, one of the largest corporate foundations in the U.S. In 2018, the Wells Fargo Foundation donated $444 million to accelerate economic opportunity and success in underserved communities with a strategic focus on housing affordability, small business growth, and financial health.

    With more than two decades of experience in philanthropy, employee engagement, and corporate citizenship, Flores is responsible for combining financial resources with business expertise to help underserved and diverse entrepreneurs expand their impact on the economy and ability to provide jobs. Most recently, she served as Head of Community Affairs and Corporate Social Responsibility at Bank of the West, where she led the company’s strategy for small business engagement and impact, including the creation of a new $30 million investment fund with community development financial institutions. Prior to her role with Bank of the West, Flores spent a decade in community development at Citigroup and also held roles at the Congress of California Seniors, Greenlining Institute, and the California State Legislature.

    An active community leader, Flores is based in San Francisco and serves on the Board of Directors for the Ocean Conservancy and volunteers as a mentor for start-up entrepreneurs through the Nasdaq Entrepreneurial Center’s Milestone Maker program.

    She received a bachelor’s degree in Political Science from the University of California–Berkeley and an MBA from the FW Olin Graduate School of Business at Babson College in Wellesley, Massachusetts.

    Wells Fargo Open for Business: Community Development Financial Institutions (CDFIs) Program

    https://www08.wellsfargomedia.com/assets/pdf/about/corporate-responsibility/open-for-business-fund.pdf

    Wells Fargo will donate processing fees generated from the Paycheck Protection Program (PPP) to support nonprofits, including Community Development Financial Institutions (CDFIs), helping small businesses recover from the economic, health and social crises of 2020. We anticipate awarding approximately $250 million in grants to CDFIs, CDFI intermediaries and special‐purpose funds formed by CDFIs for rapid response to small business. The size of grants will depend on an organization’s capacity, geographic scope and alignment with the program selection criteria as provided below. Grants, generally ranging from $250,000 up to $5,000,000 will be awarded.

    As the CEO of Wells Fargo, I can commit that our company will do all we can to support our diverse communities and foster a company culture that deeply values and respects diversity and inclusion. …I firmly believe a diversity of insights and perspectives will drive Wells Fargo to the best ideas and outcomes possible. Part of our journey is about being able to listen to the experiences of others and having honest, open dialogue across differences.    ~Charlie Scharf 

    Wells Fargo & Company (NYSE: WFC) is a diversified, community-based financial services company with $1.97 trillion in assets. Wells Fargo’s vision is to satisfy our customers’ financial needs and help them succeed financially. News, insights, and perspectives from Wells Fargo are also available at Wells Fargo Stories. https://stories.wf.com/

    This podcast interviews Kenneth Thomas, Ph.D., of Community Development Fund Advisors, one of our pioneers of the Community Reinvestment Act (CRA) to share a high-level overview of CRA Reform now that the Office of the Comptroller of the Currency (OCC) released its final rule. This episode highlights CRA modernization, interagency positions, politics and coronavirus recovery efforts.

    CRA TODAY
    SHOWNOTES: Episode 6: CRA Modernization and COVID Recovery Efforts Collide

    This podcast interviews Ken Thomas, Ph.D., of Community Development Fund Advisors, one of our pioneers of the Community Reinvestment Act (CRA) to share a high-level overview of CRA Reform now that the Office of the Comptroller of the Currency (OCC) released its final rule. This episode highlights CRA modernization, interagency positions, politics and coronavirus recovery efforts.  

    As so many of us are working with our banks to support our local communities recover and re-open yet CRA Reform is now at the forefront, especially for the OCC regulated entities. This episode is focused on 4 key elements, starting with a little politics, and then shifting to solutions and impact:  

    1. CRA Reform-Timing and Political Considerations 
    2. OCC’s Final Rule Framework 
    3. FDIC FRB OCC Interagency Future Considerations
    4. Community Development Impact and COVID Recovery Thoughts 

    Here are a few links to take a deeper dive into key concepts and resources: 

    Office of the Comptroller of the Currency Press Release, Comptroller of the Currency Joseph M. Otting Resignation Announcement 

    https://www.occ.treas.gov/news-issuances/news-releases/2020/nr-occ-2020-66.html

    Office of the Comptroller of the Currency, Community Reinvestment Act Final Rule 12 CFR Parts 25 and 195

    https://www.occ.gov/news-issuances/federal-register/2020/nr-occ-2020-63a.pdf

    Community Development Fund Advisors https://communitydevelopmentfund.com/

    Ken Thomas Ph.D. LinkedIn https://barefootbeachcafe.com/menu/

    CRA Today https://cratoday.com/

    Linda Ezuka LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/

    Click here to access a free download “30 Creative Ways Beyond Forbearance and Forgiveness Programs to Support COVID Recovery

    Just when we were all getting ready to sit down and draft our OCC and FDIC CRA Comment Letters in preparation for our April 8th deadline, the unfathomable happened: our world shifted to all things COVID-19. Linda shares her thoughts around bank’s role in recovery efforts and provides details of the interagency regulatory response under the CRA.

    CRA TODAY
    SHOWNOTES: Episode 5: Community Action and Partnerships Prevails as Banks Mobilize to Respond to COVID-19

    Community Action and Partnerships Prevails as Banks Mobilize to Respond to COVID-19

    Just when we were all getting ready to sit down and draft our OCC and FDIC CRA Comment Letters in preparation for our April 8th deadline, the unfathomable happened: our world shifted to all things COVID-19.  Linda shares her thoughts around bank’s role in recovery efforts and provides details of the interagency regulatory response under the CRA.
     
    CRA Comments Letters are due April 8, 2020-Click here to learn more and to submit your comments:    https://www.regulations.gov/docket?D=OCC-2018-0008
     
    On March 9, 2020, the federal financial institution regulatory agencies (THE FRB, OCC AND THE FDIC) and state bank regulators issued a statement to encourage financial institutions to meet the financial services needs of their customers and members in areas affected by COVID-19.  Click here to learn more and review the formal statement: https://www.occ.treas.gov/news-issuances/bulletins/2020/bulletin-2020-19.html
     
    The Federal Financial Institutions Examination Council (FFIEC) also issued a recent press release to support banks during this unprecedented time:  https://www.ffiec.gov/press/pr032520.htm

    Troubled Debt Restructurings Interagency Supervisory Guidancehttps://www.fdic.gov/news/news/financial/2013/fil13050.html 

     

    So, as we continue to navigate these unprecedented times, let continue to be curious… Let’s not forget to pause and ask ourselves as bankers, community development advocates and nonprofit leaders:  WHAT ELSE IS POSSIBLE?  

    • How can we partner with CDFIs to extend the traditional boundaries of capital where it is most needed? 
    • How can we leverage programs and services provided by social service agencies, federal health clinics and community action agencies to meet the foundational needs of the most economically vulnerable?  
    • How can we further lift local Community Foundation and philanthropic emergency response funds to invest capital for the greatest good? 

    This pandemic is an unprecedented challenge for the entire country and the world, but especially for our most economically fragile people, our local organizations and businesses in our communities. And it is natural about now to also ask what we can do as families, as individuals and just as a good human… What else can we do to support our most vulnerable? 

    Although we need all businesses, large and small to come through this crisis as a going concern, now more than ever, the small business community needs your support. If you can, shop small and local.  Heck, even let those kids and teenagers chose which restaurants they want to take turns supporting with a swift take out order for your next family meal.   Support the people and businesses you love… and above all else, be thankful for those walls that surround you and the roof that hovers over those you hold the most dear (even though they may be driving you a bit crazy…!) 

    Our guest for this episode is Richard Woo, retired CEO of the Russell Family Foundation. During his tenure at the foundation, he learned first-hand the power of impact investing and shares his early explorations, community partnership and impressive ROI results.

    CRA TODAY
    SHOWNOTES: Episode 4: Impact Investing and How Powerful It Can Be For The Community

    Impact investing, which seeks to generate social and/or environmental benefits while delivering a financial return, is expanding as a promising tool for both investors and philanthropists.   Stakeholders in community development have much to gain from learning more about this tool to fund mission critical projects in their communities. Some estimates value the current impact investing market at nearly $9 trillion in the U.S. alone.

     

    Our guest for this episode is Richard Woo, retired CEO of the Russell Family Foundation.  During his tenure at the foundation, he learned first-hand the power of impact investing and shares his early explorations, community partnership and impressive ROI results. 

     

    Richard starts with an overview of social impact investing and then shares the importance of curiosity and exploration as entities explore their roles in impact investing and the importance of aligning your portfolio with your values and purpose.  

     

    And it is important to note, that while he outlines examples on how financial institutions, CDFIs and nonprofits are involved in this space, any investor, philanthropic, enterprise, individual, government entities, or commercial enterprises (banks, small businesses etc.) can engage in social impact investing.

     

    Here are the links to the projects mentioned and follow up resources to learn more about social impact investing:

     

    The Russel Family Foundation

    The Russel Family Foundation – The Impact Investing Case Study 

    LinkedIn-Richard Woo  

    Mission Investors Exchange – Impact Investing, share deals and practices 

    Confluence Philanthropy 

    Greater Tacoma Community Foundation

    Canopy – a group of 15 impact investing foundations from Washington, Oregon, Alaska, and newly Hawaii 

    Puyallup Watershed Initiative 

     

    I leave you with these related questions: 

     

    What do you value and what would like your capital to do in this world? 

    What actions are you taking for the greater good? 

    Is there a way to invest your financial capital to pilot, expand, and leverage for community impact?

    Looking beyond financial returns, do you know where your personal 401k retirement accounts are invested and what impact they have in the world?   

     

    Mark shares a few stories of his CDFI journey and will share his new CDFI Friendly Cities initiative and his deep thoughts about community development.

    CRA TODAY
    SHOWNOTES: Episode 2: CDFI Friendly Cities with Mark Pinsky

    Mark Pinsky shares “CDFI Friendly Cities” a fresh approach to community development

    Mark Pinsky shares a few stories of his CDFI journey and will share his new CDFI Friendly Cities initiative and his deep thoughts about community development.

    Mark will share his insights on how communities gain access to valuable and financing for small business, commercial real estate and housing and how you facilitate and lower the costs for CDFIs to expand their coverage and increase their financing activity into new, underserved CDFI markets. He will also share how CDFI investors expand opportunities and attract new investors who have previously lacked knowledge of and opportunities to invest in CDFIs.

    Join us on a CDFI journey to transform communities through the power of economic development and the Community Reinvestment Act. Get ready for a fun and meaningful listen!

    Here are a few highlights and links to explore:

    Mark Pinsky

    Five/Four Advisors White Paper on the CDFI Friendly City Model

    Bloomington Urban Enterprise Association

    Opportunity Finance Network

    Community Foundation Bloomington & Monroe County

    Mayor John Hamilton of Bloomington, IN

    Chuck Matthei, Equity Trust 

    CDFI Fund, What are CDFIs?  

    CRA Today – https://cratoday.com/

    Maurice Jones of LISC shares an overview of the “new” Opportunity Zone program and the hopes of real community development impact.

    CRA Tips is a weekly series of quick podcast episodes for busy CRA practitioners to revisit core CRA concepts and implement best practices.

    The CRA Tips

    The CRA Tips

    As most of you know, the public file is a straightforward requirement of the CRA. Its purpose is to disclose basic information about your bank, its products and services, and how you serve the community. The file includes a wide variety of information, and here I discuss the technical requirements, what not to include, and recommendations around best practices.
    Episode 82: CRA Tips: Less is More - Perfecting Your CRA File by Cutting the Clutter

    As most of you know, the public file is a straightforward requirement of the CRA. Its purpose is to disclose basic information about your bank, its products and services, and how you serve the community. The file includes a wide variety of information, and here I discuss the technical requirements, what not to include, and recommendations around best practices.

    Tips include putting together a checklist so you don’t miss any necessary requirements. I also go over additional information you should make available to the public, the two typical versions of a public file, how to handle requests for copies of your public file, and how to cut down on unnecessary clutter.

    CRA Hub: https://cratoday.com/hub

    CRA Today Website: https://cratoday.com/hub

    Linda 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.

    In a recent CRA fundamentals office hours session, we discussed current practices around community development services. One bank professional asked why, at her last bank, they counted the number of hours of qualified community development services, but at her current bank, they count both the number of occurrences and hours.
    Episode 80: CRA Tips: CRA Services Hours, Events, or Instances? What the What?!?
    In a recent CRA fundamentals office hours session, we discussed current practices around community development services. One bank professional asked why, at her last bank, they counted the number of hours of qualified community development services, but at her current bank, they count both the number of occurrences and hours.

    Both of those banks were FDIC regulated. In the past, I was with an FDIC bank, and we counted services by hours. If you’re confused, you’re not alone. Here, I explain how to look at your bank’s performance evaluation and past exams for context. I also talk about how to think about instances, how to ask regulators for guidance, and how to proceed if you want to make changes in the future.

    If you want to explore similar CRA compliance questions in a community of CRA professionals, you may want to consider joining the CRA Hub. It is our flagship CRA training and is the place to master the CRA, get exam ready and learn how to leverage capital for the greater good.

    CRA Hub: https://cratoday.com/hub

    CRA Today Website: https://cratoday.com/hub

    Linda 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.

    In a recent webinar, I received some great tips from a panel of women who shared their journeys in leading their CRA program. I was inspired to pass them along here and share the importance of building a solid team around you in your own program.
    Episode 79: CRA Tips: You are not alone...

    In a recent webinar, I received some great tips from a panel of women who shared their journeys in leading their CRA program. I was inspired to pass them along here and share the importance of building a solid team around you in your own program.

    I start with a story about a private client who had to pull together her own team and the challenges that she faced. I share the three lines of defense CRA officers should put into place and the importance of reflecting on the current state of your CRA program.

    I also discuss why running a CRA program is like a relay, why charitable donations to market leaders could lead to more buy-in, and how assembling a working group to talk about CRA helps you look at things from different vantage points.

    Another great tip is to hold smaller, weekly meetings with key stakeholders to share CRA program wins and hot topics. Additionally, bringing market presidents to exit meetings helps them understand how their work impacts the ultimate CRA rating.

    For more information on Kadince Webinars: https://kadince.com/webinars

    CRA Hub: https://cratoday.com/hub

    Linda 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.

    Here, I provide a couple of suggestions on how to prepare for your exam at the most basic level. I discuss where to place your focus when it comes to gathering information, cultivating a culture of compliance, and conducting a self-assessment. I also talk about CRA data integrity and why it’s so important.
    Episode 78: CRA Tips: Finish Strong: How to Prepare for Your Next CRA Exam
    In case you missed it, I recently published an article in the ABA Compliance Magazine earlier this year. It was all about preparing for your CRA exam in the midst of regulatory uncertainty. We sure do have a lot of uncertainty swirling around these days. Although it’s easy to get distracted, I recommend you stay laser-focused on your CRA program and finish strong with your current exam cycle.

    Your bank will likely have one more exam under the current rules-do you know where your strengths and gaps are in each of your assessment areas?

    Here, I provide a couple of suggestions on how to prepare for your exam at the most basic level. I discuss where to place your focus when it comes to gathering information, cultivating a culture of compliance, and conducting a self-assessment. I also talk about CRA data integrity and why it’s so important.

    American Bankers Association Bank Compliance Magazine article: https://cratoday.com/finish/

    CRA Hub: https://cratoday.com/hub

    Linda 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.

    I recently walked a CRA officer through a potential loan transaction in partnership with a community development corporation, otherwise known as a CDC. As a CRA professional, you may be approached by CDCs directly, or CDCs might approach your lenders first. Either way, these mission based organizations are great partners in community development.
    Episode 77: CRA Tips: CDCs - Your Partners in Community Development

    I recently walked a CRA officer through a potential loan transaction in partnership with a community development corporation, otherwise known as a CDC. As a CRA professional, you may be approached by CDCs directly, or CDCs might approach your lenders first. Either way, these mission based organizations are great partners in community development.
    It is estimated that there are 4,500 CDCs nationwide, and there’s likely one or several in your state. Here, I cover what CDCs are, how they came about, and what they focus on. I discuss how they partner with other community development initiatives to drive local impact.

    Community Development Corporations (CDCs) Resources:
    The term “community development corporation” means a private, nonprofit corporation whose board of directors is comprised of business, civic, and community leaders, and whose principal purpose includes the provision of low-income housing or community economic development projects that primarily benefit low-income individuals and communities. 34 U.S. Code § 12211

    https://www.naceda.org/index.php?option=com_dailyplanetblog&view=entry&category=bright-ideas&id=25%3Awhat-is-a-community-development-corporation-&Itemid=171

    https://case.edu/ech/articles/c/community-development-corporations

    https://www.urban.org/sites/default/files/publication/60731/410638-Community-Development-Corporations-and-their-Changing-Support-Systems.PDF

    Here is one of my favorite resources mentioned in this episode:
    https://www.dallasfed.org/~/media/documents/cd/pubs/craloan.pdf

    Here is another article that highlights the importance of partnering with your lenders to drive community development impact:
    https://cratoday.com/driving-impact-and-building-trust-the-power-of-collaboration-between-compliance-professionals-and-lenders-in-community-development-lending/

    CRA Hub: https://cratoday.com/hub

    Linda 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.

    Here, I share how to classify these PPP loans and how to tell if your PPP loans count as community development loans. I also discuss mining for other community development loans and “hooks”. Make sure to check out the SBA’s guidance on PPP loans, linked below.
    Episode 75: CRA Tip: The Pandemic May Be Over but SBA PPP Loans May Still Have an Impact During Your Next Exam

    Your previous CRA exam may not have included pandemic activities, but your next one is likely to include activity around the SBA’s Paycheck Protection Program, or PPP. You can get credit for participating in the PPP under your CRA program, which translates into CRA lending performance. Your next exam would highlight your participation in the program, and you would also account for the individual loans that were deployed under the program, either as small business lending performance or community development loan activities.

    Here, I share how to classify these PPP loans and how to tell if your PPP loans count as community development loans. I also discuss mining for other community development loans and “hooks”. Make sure to check out the SBA’s guidance on PPP loans, linked below.

    Frequently Asked Questions (FAQs) on the Small Business Administration’s Paycheck Protection Program – March 3, 2021: https://www.fdic.gov/coronavirus/smallbusiness/faq-sb.pdf

    CRA Today Website: https://cratoday.com/

    CRA Hub: https://cratoday.com/hub

    Linda 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.

    Recently, I was approached by a CRA professional in the industry who was about to be examined. They were working on compiling all their community development loans, and they got a bit turned around when reviewing their loans to nonprofit organizations as asked for guidance.
    Episode 74: CRA Tips: What "hooks" could a loan to a nonprofit fall under?

    Recently, I was approached by a CRA professional in the industry who was about to be examined. They were working on compiling all their community development loans, and they got a bit turned around when reviewing their loans to nonprofit organizations as asked for guidance.

    I advise bankers to conduct a 100% review of a bank’s loans to nonprofit organizations due to the charitable nature of the nonprofit entities. This doesn’t guarantee community development qualification but I find many of these loans are prospects to dig deeper into. In this episode, I break down each community development hook, including affordable housing, community services, economic development and revitalization. I also walk through how to properly document non-profit loans if they fall under one of these community development categories.

    We spend a lot of time within the CRA Hub vetting community development loan prospects and work together to find the most appropriate and most defensible community development “hook” that will withstand examiner scrutiny. Enjoy the episode and happy CD loan mining!

    CRA Today Website: https://cratoday.com/

    CRA Hub: https://cratoday.com/hub

    Linda 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.

    Here, I outline the best practices I shared in response to this question. Although ISBs aren’t required to report, it’s important for you to know what your performance is before the examiners. Pulling your data on at least an annual basis and reflecting on some of the key performance standards is highly recommended.
    Episode 73: CRA Tips: I'm an ISB, do I really need to look at my lending performance?
    I recently received a question from someone newer to the CRA within an intermediate small bank (ISB). They knew they didn’t have to report their lending data but wanted to know if they needed to actually review it. Additionally, if they did need to review it, they wanted to know how they would do so. I referred them to the Banker’s Quick Reference Guide I’ve linked below. It’s one of my favorites because it’s a quick review of all performance standards and shows you how examiners evaluate performance.

    Here, I outline the best practices I shared in response to this question. Although ISBs aren’t required to report, it’s important for you to know what your performance is before the examiners. Pulling your data on at least an annual basis and reflecting on some of the key performance standards is highly recommended.

    A Banker’s Quick Reference Guide to CRA, Federal Reserve Bank of Dallas: https://www.dallasfed.org/~/media/documents/cd/pubs/quickref.pdf

    CRA Today Website: https://cratoday.com/

    CRA Hub: https://cratoday.com/hub

    Linda 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.

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

    Episode 72: CRA Tips: Naturally Occurring Affordable Housing and CD Loans

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

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

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

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

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

    CRA Today Website: https://cratoday.com/ 

    CRA Hub: https://cratoday.com/hub

    Linda 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.

    In the past, regulations narrowly defined the provision of financial services. To qualify a community development service, it has to have a primary purpose of community development, be offered on behalf of the bank, and must be related to the provision of financial services. Back then, this meant traditional banking, like creating a spreadsheet or something financial in nature. Here, we cover the updated definition of the provision of financial services to expand eligible community development service activities.

    Episode 71: CRA Tips: CRA Services-What exactly does the provision of financial services mean?

    In the past, regulations narrowly defined the provision of financial services. To qualify a community development service, it has to have a primary purpose of community development, be offered on behalf of the bank, and must be related to the provision of financial services. Back then, this meant traditional banking, like creating a spreadsheet or something financial in nature. Here, we cover the updated definition of the provision of financial services to expand eligible community development service activities.

    Interagency Questions and Answers Regarding Community Reinvestment: 

    https://www.govinfo.gov/content/pkg/FR-2016-07-25/pdf/2016-16693.pdf

    The specific citation from the above linked resources referenced within this podcast episode is the following:

    • ll.12(i)–3: What are examples of community development services?

    A3. Examples of community development services include, but are not limited to, the following:

    • Providing technical assistance on financial matters to nonprofit, tribal, or government organizations serving low and moderate-income housing or economic revitalization and development needs
    • Providing technical assistance on financial matters to small businesses or community development organizations, including organizations and individuals who apply for loans or grants under the Federal Home Loan Banks’ (FHLB) Affordable Housing Program
    • Lending employees to provide financial services for organizations facilitating affordable housing construction and rehabilitation or development of affordable housing
    • Providing credit counseling, homebuyer and home maintenance counseling, financial planning or other financial services education to promote community development and affordable housing, including credit counseling to assist low- or moderate-income borrowers in avoiding foreclosure on their homes
    • Establishing school savings programs or developing or teaching financial education or literacy curricula for low- or moderate-income individuals; and
    • Providing foreclosure prevention programs to low- or moderate-income homeowners who are facing foreclosure on their primary residence with the objective of providing affordable, sustainable, long-term loan modifications and restructurings.

    [Specific examples related to the provision of financial services] 

    Examples of technical assistance activities that are related to the provision of financial services and that might be provided to community development organizations include

    • serving on the board of directors
    • serving on a loan review committee
    • developing loan application and underwriting standards
    • developing loan-processing systems
    • developing secondary market vehicles or programs
    • assisting in marketing financial services, including development of advertising and promotions, publications, workshops and conferences
    • furnishing financial services training for staff and management
    • contributing accounting/ bookkeeping services
    • assisting in fund raising, including soliciting or arranging investments; and
    • providing services reflecting a financial institution’s employees’ areas of expertise at the institution, such as human resources, information technology, and legal services. Refer to Q&A §ll.24(a)—1 for information about how retail services are evaluated under the large institution service test.

    Community Development Financial Institutions are also mentioned in this episode.  

    Community development financial institutions (CDFIs) are lenders with a mission to provide fair, responsible financing to rural, urban, Native, and other communities that mainstream finance might not traditionally reach. 

    CDFIs specialize in lending to individuals, organizations, and businesses in under-resourced communities, offering clients financial education, business coaching, and low-interest rate loans that increase economic potential and help build wealth.

    CDFI lending leads to small businesses and homeownership, creates living wage jobs, supports the development of schools, grocery stores, and health care centers, finances climate change solutions, and so much more:  https://www.ofn.org/what-is-a-cdfi/

    CRA Today Website: https://cratoday.com/

    CRA Hub: https://cratoday.com/hub

    Linda 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.

    When it comes to community development services documentation, there isn’t a one-size-fits-all solution. Many of our bankers will use various annual reports, tax returns, and even websites to gather the information they need. I recommended that this CRA officer go back and embed a process, so she gets what she needs to prove the primary purpose of community development.

    Episode 70: CRA Services: If It’s Not Documented, It Didn’t Happen
    I received an email from a CRA officer who recently took over a CRA program. Although this individual is a seasoned compliance professional, she’s new at running a CRA program, and the exam was right around the corner. Here, I share her journey and tips to document community development activities. 

    When it comes to community development services documentation, there isn’t a one-size-fits-all solution. Many of our bankers will use various annual reports, tax returns, and even websites to gather the information they need. I recommended that this CRA officer go back and embed a process, so she gets what she needs to prove the primary purpose of community development. 

    This helps when time is of the essence and you need to pull information together quickly. Shoring up your program prevents scrambling at the last minute. When we get that notice of the CRA exam, proper documentation can be a lifesaver. 

    Interagency Questions & Answers Regarding Community Reinvestment (Questions and Answers) were released by the staffs of the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency on July 15, 2016, to provide guidance to financial institutions and the public.

    Guidestar.org is also a good resource to learn more about nonprofit organizations, their mission, and even review their IRS Form 990 (their version of a tax return).

    Outstanding: A Practitioner’s Guide to CRA Exam Readiness: https://a.co/d/cRze5F1

    CRA Today Website: https://cratoday.com/

    CRA Hub: https://cratoday.com/hub

    Linda 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.

    We created this checklist to support your focus on the most pressing issues faced by your bank and to spark critical conversations with key stakeholders within the bank to determine your path forward.
    Episode 69: CRA Tips: Regulatory Change Part III: Operational and Financial Risks

    As referenced in the episode, you may want to download our free regulatory change checklist: https://cratoday.com/regulatory-change-checklist/

    We created this checklist to support your focus on the most pressing issues faced by your bank and to spark critical conversations with key stakeholders within the bank to determine your path forward.

    There are several operational and financial risks associated with the new proposed CRA rules. First, you’ll need to formalize our compliance documentation and map out your CRA framework. Taking a bird’s eye view of your CRA program from a compliance management system (CMS) standpoint will help you make sure you have proper oversight and integration.

    You’ll also need to address your systems and vendor reliance to adjust to the proposed increase in reporting and performance analytics. Staffing turnover, the higher cost of talent, and additions to staff also need to be taken into careful consideration. There will be an increased cost of compliance within business units, and certainly within your CRA program, so it’s important to have conversations with executive management and key stakeholders.

    Make sure your bank is adequately resourced to maintain CRA performance and increase the proposed provisions. Planning now will help you finish strong in the current regulatory environment and adapt to upcoming regulatory changes. 

    Download the checklist today and continue to explore the implications of regulatory changes. 

    We also have the CRA Hub to support your path through regulatory change! We’ve got you!

    CRA Today Website: https://cratoday.com/

    CRA Hub: https://cratoday.com/hub

    Linda 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.

    It’s going to be a year-end like no other, and regulatory change continues to be front and center. There are several key compliance risks to be aware of and elements to reflect upon as a CRA officer. Regulators will continue to enhance their focus on oversight, supervision, and enforcement.

    Episode 67: CRA Tips: CRA Tips: Regulatory Change Part I: Compliance Risk - The Only Constant is Change

    It’s going to be a year-end like no other, and regulatory change continues to be front and center. There are several key compliance risks to be aware of and elements to reflect upon as a CRA officer. Regulators will continue to enhance their focus on oversight, supervision, and enforcement.

    The adaptation to new regulations, market disruption, and expected lack of clear guidance and training from regulators will increase our risk to regulatory change. Our regulators are also adapting, and whenever there’s something new, there will be uncertainty on both sides as the changes are implemented. State agencies are also getting more involved in regulatory oversight and coming up with their own approaches to CRA and banking. There’s also an increase in fair lending risk and an increased interest in climate change and the impact of natural disasters on lower income populations.

    Listen in to part one of this three part series on regulatory change.

    I have also compiled a free resource that will support you as you start to prepare your bank for this monumental shift in managing risk and your CRA program. Get the CRA Regulatory Change Checklist here: https://cratoday.com/regulatory-change-checklist/

    CRA Today Website: https://cratoday.com/

    CRA Hub: https://cratoday.com/hub

    Linda 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.

    In this episode, we’re taking a deeper dive into the economic development hook, which is often an overlooked aspect of community development loans. However, it plays a crucial role in strengthening local economies. Here, you’ll learn how to identify community development loans that were originated for small businesses to support your community development loan portfolio.

    Episode 66: CRA Tips: Revisiting the Fundamentals: The Most Overlooked CD Hook
    In this episode, we’re taking a deeper dive into the economic development hook, which is often an overlooked aspect of community development loans. However, it plays a crucial role in strengthening local economies. Here, you’ll learn how to identify community development loans that were originated for small businesses to support your community development loan portfolio.

    Remember, when qualifying for a CD loan under the economic development hook, you’ll need to meet the size and purpose test. The criteria to meet the test are: 

    Credit write ups don’t usually include salaries or job information, CRA professionals will have to make a few reasonable assumptions and document their approach for an examiner’s review.  The interagency Q&A has guidelines to help frame your approach. This episode includes some examples of common small businesses that qualify under the economic development hook.You can reference the Bureau of Labor Statistics to document information on representative jobs and income levels based on the loan originated and its local demographics and economic statistics.

    CRA Today Website: https://cratoday.com/

    CRA Hub: For more Community Reinvestment Act training resources, check out the Hub! https://cratoday.com/hub

    Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/

    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 will lay the foundation for community development loans as it relates to your CRA program.

    Episode 65: CRA Tips: Revisiting the Fundamentals: A Community Development Loan Primer

    This episode will lay the foundation for community development loans as it relates to your CRA program. 

    Community development loans must have a primary purpose of community development. You will need to follow the loan proceeds to the intended primary impact that resulted from originating a loan to the borrower.

    An “oldie but goodie” resource is the Office of the Comptroller of the Currency’s Community Developments Fact Sheet published by the Community Affairs team.

    Within this resource, the primary purpose of community development is defined as follows:

    Under the CRA, community development activities

     

    • Support affordable housing for low- or moderate-income (LMI) individuals, including multifamily rental housing. 
    • Target community services for LMI individuals. 
    • Promote economic development by financing businesses or farms that have gross annual revenues of $1 million or less or that meet the size eligibility requirements of the U.S. Small Business Administration’s (SBA) Small Business Development Company or Small Business Investment Company (SBIC) programs. 
    • Revitalize or stabilize LMI geographies; designated disaster areas; or distressed or underserved nonmetropolitan middle-income geographies designated by the OCC, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation. [Source OCC publication linked above]

    This guide from the Federal Reserve Bank of Dallas is an excellent resource and one I still use several times a month.

     

    This publication is intended as a quick guide for identifying CRA loan data reporting categories. It is designed for bank CEOs, presidents, CRA and compliance officers, and others who have an interest in the CRA loan data collection process. Refer to Regulation BB, Regulation C, and the instructions for the preparation of the Consolidated Reports of Condition and Income for more detailed information. 

    CRA Today Website: https://cratoday.com/

    CRA Hub: For more Community Reinvestment Act training resources, check out the Hub! https://cratoday.com/hub

    Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/

    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.

    Episode 62: What exactly is the BLS and how does it relate to the CRA?

    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.

    Episode 60: How to Leverage Internal Expertise to Drive External Impact

    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.

    Episode 59: Economic Development as a Key to Community Development Services

    There are a wealth of opportunities to serve aspiring entrepreneurs and established small businesses!

    Episode 58: How to Increase your CRA Services By Partnering with Impactful Organizations

    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?

    Episode 57:  I Bet You Are Underreporting Your Community Development Loans… Most Banks Are Too!

    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.

    Episode 56: Key Departments Critical to A Sound CRA Training Program

    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.

    Episode 53: It’s National Financial Capability Month…Where Do I Begin?

    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.

    Episode 51: CRA Plan Checklist Inside!

    It’s time to build your 2022 CRA strategy and action plan! Here are your next steps…

    Episode 50: Haven’t Developed a CRA Plan Yet?

    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.

    Episode 49: Congrats! Take The Day Off!!

    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!

    Episode 48: Just 120 Business Hours Left…

    Why does February only have 28 days? It seems so wrong as we are up against our March 1st CRA data reporting deadline!

    Episode 47: Just 10 Business Days Left…

    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.

    Episode 46: You Only Have Three Weeks Left…

    Let’s refocus our time on your CRA data integrity and, for some of you, your annual CRA data submission.

    Episode 45: Three Ways to Supplement Your CRA Program Today

    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.

    Episode 44: How to Build the Culture of Compliance Within the Bank

    So, how do you actually build the culture of compliance within your bank?

    Episode 43: How to Add a Team Member to Your CRA Mighty Team of One

    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.

    Episode 42: How to Grow Your Team Without Adding Staff

    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.

    Episode 41: How to Do the Undoable Deal

    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.

    Episode 40: It Takes a Village…Do You Know Who You Can Trust?

    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.

    Episode 39: Community Development Finance: Yes, It’s Part of Your Job Too!

    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.

    Episode 37: I Failed My CRA Data Integrity Exam – Now What?

    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.

    Episode 36: Best Practices to Ensure CRA Data Integrity

    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?

    Episode 35: The Secret to a Smooth CRA Data Integrity Exam!

    I bet you, 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?

    Episode 34: How to Ace Your Next CRA Data Integrity Exam!

    As you know, before each exam, your regulators will conduct a review of your lending data to ensure that it is accurate enough to be relied upon to determine your lending performance. The regulators have a very specific approach that is delineated within the Consumer Compliance Handbook. 

    Episode 33: The Devil Is in the Details but Don’t Let It Get to Your Data, Too!

    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.  The bank is subject to reputational risk due to data errors that may lead to costly remediation and erode consumer confidence.

    Episode 32: Creative Items to Add to Your CRA Committee Meeting Agenda

    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.

    Episode 31: Three Documents You Must Have for Your CRA Program

    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.

    Episode 30: Repurpose Your CRA Self Assessment To Build Awareness and Buy-In

    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.

    Episode 29: Five Key Resources To Inform Your CRA Self Assessment

    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.

    Episode 28: Choices. Make One and Let’s Get to Work!

    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.

    Episode 27: Look Back to Learn How to Look Forward

    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.

    Episode 26: Strategy Is a Commodity, Execution Is an Art

    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.

    Episode 25: Don’t Leave This for the Examiners to Decide

    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.

    Episode 24: CDFIs Are Changing The World. Will You Join Them?

    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.

    Episode 23: $2.2 Billion Is at Stake for Low-Income Taxpayers

    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.

    Episode 22: The Average American Has $90,460 In Consumer Debt

    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.

    Episode 21: One Super Simple Community Development Service You Might Be Under-Reporting

    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.

    Episode 20: Can the Countless Hours We Spent on the SBA PPP Count? You Might Be Surprised…

    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.

    Episode 19: Three Community Development Services You’d Be Surprised Don’t Count

    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:

    Episode 18: Are You Unintentionally Under-Serving Low- and Moderate-Income (LMI) Communities?

    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?

    Episode 17: Three Ways To Inspire More Community Development Loan Activities

    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.

    Episode 16: Internal Stakeholders: Who They Are And Why They Matter

    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.

    Episode 15: Community Development Loans… How Much Is Enough?

    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:

    Episode 14: Community Development Loan Mining Strategies You Don’t Want To Miss

    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.

    Episode 13: Five Must Have Strategy and Implementation Documents to Guide Your CRA Program

    As you start building or refreshing your CRA program, these internal documents can serve as a guiding light. Gather these core documents and make sure you revisit them often as you initiate new programs and build your CRA culture throughout the bank.

    Episode 12: CRA TIPS – A Series Created for CRA Practitioners

    Managing the Community Reinvestment Act (CRA) program for your financial institution can be challenging, especially if you’re new to the CRA. To support you in your CRA journey, CRA Today and Kadince have partnered to provide informative content to highlight CRA best practices and ideas to guide your CRA program.