The CRA Tips - CRA Today

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

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/

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?!?

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/

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...

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/

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?

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/

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/

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.

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/

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?

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/

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.

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/

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.

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/

(No claim to original U.S. government material)

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?

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/

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.

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/

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/

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/

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

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/

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

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:

The borrower must be considered a bona fide small business per Small Business Association (SBA) standards. You can view their standards here: U.S. Small Business Administration Table of Small Business Size Standards
The borrower or purpose of the loan must also retain or create jobs for low or moderate-income individuals

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/

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/

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.

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Linda

With over 29 years of community development experience, with an emphasis in CRA, compliance, training, community development lending, and CDFI initiatives, Linda works with financial institutions to provide comprehensive CRA training, up-to-date resources, and proven strategies to remain compliant. She helps CRA professionals master the art of the CRA, get exam and transform communities through the power of economic development.