CRA a Brief History Lynette C. Briggs, VP - Regional CRA Officer
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1 CRA a Brief History Lynette C. Briggs, VP - Regional CRA Officer August 2016
2 Community Reinvestment Act (CRA) a Brief History 2
3 Community Reinvestment Act (CRA) The Community Reinvestment Act (CRA) Brief History The Commission on Civil Rights report in 1961 found severe shortage of available credit in low and income African-American Neighborhoods and documented that lenders: Required higher downpayments, faster repayment terms, and, in some neighborhoods, refused to lend, regardless of borrower qualifications. A practice known as redlining. Redlining began in the 1930 s by the Federal Housing Administration.(FHA); although it is likely to have begun much earlier. Residential Security Maps were created by the Home Owner s Loan Corporation (HOLC) for the FHA to designate areas that were too risky to lend. Both Private and Public entities relied on these maps to determine whether or not to lend. An example: This map of New Orleans was prepared by the Federal Agency: Home Owners Loan Corporation (HOLC) ca (Source: National Archives and Records Administration ). The red color identified areas that were deemed Hazardous areas to lend. These maps were used by government and private lenders. The policy contributed to a shortage of direct lending and is alleged to be a root to urban blight in many American cities. Note: Pre-Katrina. Most of these same yellow and red areas were still some of the poorest neighborhoods in
4 HOLC Residential Security Map (October 1939-April 1940) Maywood, IL 4
5 CRA (continued) Brief History (continued): The Commission on Civil Rights report ushered in an era of many Civil Rights laws, including: The Fair Housing Act (1968), The Equal Credit Opportunity Act (1974) And, the Home Mortgage Disclosure Act (1975). It was by way of these laws, community activists like Gail Cincotta (National People s Action in Chicago) led the fight to pass and enforce the Community Reinvestment Act. Chicago is credited by some to be the birthplace of CRA These earlier reforms led to creation of the Community Reinvestment Act. Enacted by Congress October 12, 1977, the CRA was intended to address discriminatory lending patterns in communities across the nation. Revisions were made in May 1995 and again in August 2005 (12 CFR 25) to enhance enforcement. 5
6 CRA (continued) What you need to know about the CRA The CRA requires banks (insured by the FDIC) to determine and help meet the credit and banking needs of ALL segments of their defined communities, including those of low- and moderate-income households and areas, and other under-served areas within those communities. Financial institutions are required to delineate a CRA assessment area, i.e. define what the bank considers to be its community for CRA purposes. Most banks define their CRA community as the geographic areas they can reasonably be expected to service with deposit and loan products considering their branch distribution within the community. Every three years (Maximum five years) the bank s record of meeting the credit needs in all of their delineated communities is evaluated by their regulator in a CRA examination by reviewing Lending (50% of Exam) Service (25% of Exam) Investments (25% of Exam) The results of a CRA examination is public information and the CRA performance is taken into consideration by regulators, and the public, when the bank engages in certain activities such as mergers and acquisitions, branch openings/closings, etc. 6
7 CRA (continued) What you need to know (continued) Note: The Act does not provide specific benchmarks or measurements to guide a bank. The regulators take into account the context of the market and circumstances in which the bank operates. In general, the regulators will review all bank Community Development activities within three categories. Lending Investment Service must involve the professional skills of the bank employee The CRA emphasizes Community Development and its impact on low and moderateincome households and geographies (neighborhoods). Those activities that meet the definition of Community Development will be considered CRA Qualified Every bank will have one or more person(s) assigned with some or all aspects of monitoring and reporting their CRA qualified activities. 7
8 CRA (continued) CRA Qualified Community Development Activities include: Affordable Housing activities that promote affordable housing for low or moderate income households or are located in low or moderate income census tracts (neighborhoods or geographies) Community Services activities that serve low or moderate income individuals/households or geographies with essential services, including health, education, social services, job training, and day care. Economic Development activities that promote economic development by financing, primarily, small businesses that create jobs. Revitalization or Stabilization- Activities that revitalize or stabilize LMI geographies, distressed or underserved non-metro middle income areas, or designated disaster areas. Neighborhood Stabilization Program (NSP) - activities that support, enable or facilitate projects the meet the eligible uses criteria. (Please note this program has expired) 8
9 CRA Public File All financial institutions subject to the CRA are required to maintain a CRA Public File that is to be made readily available to the public upon request. The information in the Public File is required to be updated annually as of April 1. At a minimum the CRA Public File must contain the following: The public section of the bank s most recent CRA Performance Evaluation Comments on the bank s CRA performance received from the public for the current year and each of the two prior years, if any. A list of branches, their street addresses and geographies, i.e. household income level of the area the branch is located in. Any branches which have opened or closed during the current year and each of the two prior years (their street addresses and geographies) A list of all products and services provided at the banks branches (including hours of operation and any related transaction fees) The CRA Disclosure Statement for the prior two calendar years, which is a record of the banks small business, small farm, and community development lending The HMDA Disclosure Statement for the prior two calendar years, which is a record of the banks home mortgage lending activity. 9
10 CRA Public File and Availability to Public The contents of the CRA Public File must be made available to the public (upon request). By regulation, the bank must provide any requested information from the Public File within 5 calendar days. Requests may come from accountholders or non-accountholders. Requests for copies of information contained in the Public File should be printed for the requester by the branch. 10
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