The CRA Podcast with Linda Ezuka

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 Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

On October 12, 2023, we marked the 46th anniversary of the CRA. As we reflect on the past, I challenge you to consider your role in extending opportunity within your community. Here, I share a special message with our bankers who are forging an impact in our local communities. I also share a personal story about how my mother received an opportunity that changed our lives forever.While we all have different opinions on these regulations, it’s still a beautiful opportunity to change people’s lives and leverage capital for the greater good. Many come to CRA today looking to uplevel their programs, learn about best practices, and enhance their CRA training. However, once we settle in, it’s important to recommit to both the technical aspects of the CRA and the opportunity we have to provide life-changing experiences and resources to others. Here is the link to the original video message on YouTube: https://youtu.be/AJe3jCJeD9o?si=ALy85RFyyD-yAu5hCRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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/hubCRA Today Website: https://cratoday.com/ 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.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/webinarsCRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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 Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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 § 12211https://www.naceda.org/index.php?option=com_dailyplanetblog&view=entry&category=bright-ideas&id=25%3Awhat-is-a-community-development-corporation-&Itemid=171https://case.edu/ech/articles/c/community-development-corporationshttps://www.urban.org/sites/default/files/publication/60731/410638-Community-Development-Corporations-and-their-Changing-Support-Systems.PDFHere is one of my favorite resources mentioned in this episode:https://www.dallasfed.org/~/media/documents/cd/pubs/craloan.pdfHere 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 Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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 Marshall1-773-595-0974sarahhope@profoundhopeindustries.comsubdomain.profoundhopeindustries.com/digital-equityArticle: Reckoning with Digital Inequity in Place-Based Community Revitalization: https://www.jpna.org/index.php/jpna/article/view/8731% 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/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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.pdfCRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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.pdfCRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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.pdfThe 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/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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/cRze5F1CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

Regulators are continuing to enhance their focus on oversight, supervision, and enforcement, and the CRA is no exception. We expect this increased scrutiny to ramp up throughout 2023. What was acceptable before is no longer acceptable in today’s environment, and the bar has been raised. Embedded CRA rating deflation in the new proposed CRA rule opens us up to more reputational risk if we aren’t able to get out and serve our communities.There’s increased pressure on banks to defend their current banking practices and the way they redeploy capital into local communities in an equitable way. This translates into more community input and expectations, which increase reputational risk. We need to consider this as we work to build out our CRA strategic plans and adapt to the new rule once it’s implemented. Included here are some strategic discussion points that you may wish to have with your key stakeholders.Listen in to part two 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/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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 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: 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 StandardsThe borrower or purpose of the loan must also retain or create jobs for low or moderate-income individualsCredit write ups don’t usually include salaries or job information, CRAs have to make their own assumptions. The CRA Q&A has tools and guidelines to help you make the best assumptions possible. Here, I include 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. 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/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

This episode 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 to 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/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

NCRC Community Development Fund, a subsidiary of the National Community Reinvestment Coalition, lends primarily to Black, Latino, women, and immigrant entrepreneurs and business owners throughout the country with its mission to help bridge the racial wealth divide by supporting entrepreneurship and affordable homeownership in America’s underserved communities.Its new lending platform – for which it is also building an algorithm to determine loan eligibility – stands to make the roughly 10-person operation more efficient, Marisa Calderon, NCRC CDF’s executive director, said in a recent interview.This episode of the CRA Podcast addresses the promise of CDFI lending, partnerships with financial institutions to support the continuum of capital for disadvantaged communities, and how the Community Development Fund is also building a new lending platform leveraging AI to not only support efficiencies in their operation but also for others in the CDFI industry. Marisa Calderon’s Bio and ExperienceMarisa Calderon is an experienced executive who is regularly recognized, awarded and cited nationwide for her expertise in the housing and financial services industries. She has over two decades of experience dedicated to the issues of economic mobility and bridging America’s racial wealth gap. Marisa Calderon is the executive director at NCRC Community Development Fund (NCRC CDF), a nonprofit, U.S. Treasury-certified community development financial institution (CDFI) that provides loan capital to expand access to affordable homeownership, which helps Black-, Brown- and woman-owned businesses thrive. Under her leadership in her first 18 months at NCRC CDF, they deployed over $17 million in capital to historically underserved Black, Latino, immigrant, and women entrepreneurs through their small business and investment programs, earning them a place on Fast Company’s list of 2022 Most Innovative Companies in the World. She is also chief of community finance and mobility at the NCRC CDF’s parent company, the National Community Reinvestment Coalition (NCRC), where her work focuses on advancing economic mobility for communities impacted by systemic inequality and disinvestment. Marisa is ranked on the Swanepoel Power 200 as one of the most powerful leaders in the residential real estate industry, and was twice named a HousingWire Woman of Influence in 2018 and 2021 for her work in increasing real estate and mortgage professionals’ understanding and appreciation of the Hispanic home-buying market. In 2021, she was named one of Diversity Journal’s Women Worth Watching in Leadership and was featured in Hispanic Stars Rising: The New Face of Power and was recognized on Women We Admire’s list of the Top 50 Women Leaders in Finance of 2022. Frequently sought out as an expert on affordable housing, lending and immigration, Marisa has been interviewed by numerous publications and media outlets, including NPR’s Marketplace and does regular public speaking at industry and general market events, including Mortgage Banker’s Association, FDIC, Consumer Federation of America, National Fair Housing Alliance, and many others. In addition to this work, Marisa is also a board member of the non-partisan political action committee, Latinas Lead California and a Senior Advisor to America’s Homeowner Alliance.CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

This episode of the CRA Podcast highlights the community development work of Joshua Kummer of Bankers Trust. Joshua is the bank’s CRA and Fair Banking Officer overseeing the bank’s Fair Banking Program, which includes CRA, Fair Lending, HMDA, UDAAP, and Complaint Management. You will find Joshua to be very passionate about this work and this episode shares the high impact community development partnerships he has forged within his community. Not only does he have the heart for this work; you will also hear how his passion and drive has helped Bankers Trust sustain an Outstanding Community Reinvestment Act (CRA) rating!Here are the programs that are referenced within the episode:Community Development Financial Institutions (CDFI) Involvement Iowa Community CapitalSolidarity Microfinance is a non-profit program of Iowa Community Capital to create economicopportunities through small business loans, training and support, and savings services.ICC's Solidarity Microfinance program provides small loans of $500 to $8000, savings services, and financial learning opportunities for eligible low-income entrepreneurs in the Greater Des Moines Metro Area. The Solidarity Microfinance program uses Grameen peer-group lending methodology and targets women entrepreneurs from diverse new resident cultures. Neighborhood Finance CorporationNFC provides unique lending programs and other services to facilitate neighborhood revitalization in Polk County and Cedar Rapids, Iowa through partnerships with residents, governments, community-based organizations, lending institutions and the business community. For more information on our programs and services, please visit our Loan Programs page. NFC is a proud Chartered Member of NeighborWorks America. TrellisTrellis (originally started as Neighborhood Housing Services of Phoenix) was formed in 1975 with help from the City of Phoenix and NeighborWorks America. NeighborWorks America is a national nonprofit organization, federally funded by appropriations from Congress that provide financial support, technical assistance and training for community-based revitalization efforts in all 50 states.Access to homeownership is for all of us. Individuals and families become stable and more economically secure; neighborhoods become vital, active communities; and cities gain jobs and tax revenues. It’s an investment with positive returns for everyone.Other Community Involvement InitiativesHOME, Inc.HOME, Inc. is the oldest private nonprofit housing organization in Des Moines. Our mission is to meet individuals and families where they are in their housing journey. We surround our clients with compassion, support, and education so they feel empowered to make a safe, stable home for themselves or their family. To accomplish our mission, we…– Provide counseling and education to help people become successful homeowners, landlords, and tenants.– Develop, rehab, and build affordable housing units.– Help families through counseling and education to become homeowners.Newtown Community Development CorporationOur mission is to help people improve their financial well-being while strengthening communities through education, counseling, coaching, and the development and stewardship of permanently affordable homes.Newtown Community Development Corporation (Newtown) is a Tempe-based nonprofit founded in 1994. Newtown is recognized throughout the Phoenix Metro Area as a leading provider of homebuyer education, homeownership counseling, credit counseling, financial coaching, financial literacy education, and down-payment assistance. Newtown is a HUD-Approved Housing Counseling Agency and adheres to national industry standards for homeownership education and counseling. Services are provided in English and Spanish.Newtown also operates an innovative Community Land Trust, which builds and renovates permanently affordable houses, providing successful homeownership opportunities for generations of lower-income families. Created in 2001, Newtown’s Community Land Trust is the largest in Arizona with homes across Maricopa County.BIOJoshua Kummer is the AVP, Fair Banking Officer at Bankers Trust; Iowa’s largest privately owned bank headquartered in Des Moines, Iowa with assets totaling over $6 billion. The bank operates branches in Central Iowa, Cedar Rapids, IA, and Phoenix, AZ, as has offices in Omaha, NE and Sioux Falls, SD. Joshua started his banking career over 11 years ago as a part-time teller while attending college. Since then, he’s held various positions including Personal Banker, Sales & Service Manager, Branch Manager, CRA Officer and now Fair Banking Officer. He holds two compliance-related certifications: Certified Community Bank Compliance Officer (CCBCO) and Fair Lending Expert (FLE). He is also involved in his community and currently sits on the Neighborhood Finance Corporation Board of Directors, Greater DesMoines Habitat for Humanity Access to Credit Committee, Iowa Bankers Association DEI Committee and Special Olympics Iowa Fundraising Committee. Joshua has a passion for ensuring customers receive fair and equitable treatment while banking with Bankers Trust and advocates for those with limited financialresources. Bankers Trust: As Iowa’s largest privately owned bank, Bankers Trust serves the personal and business banking, lending and wealth management needs of our community.Bankers Trust Core Value: CommunityWe will strive to be the best corporate citizen by supporting diverse community organizations, both financially and through employee volunteerism. We invest in the community by nurturing and encouraging growth, stability and continued success.