Community Reinvestment Act Basics. Utah Bankers Association 2015 Community Reinvestment Conference September 16,
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2 Community Reinvestment Act Basics Utah Bankers Association 2015 Community Reinvestment Conference September 16,
3 Agenda Background Information Evaluation Types Examination Process Discussion Questions 3
4 Background What is the purpose? Why does it matter? 4
5 Assessment Area (AA) Delineation An AA must consist of: An MSA, An MD, or One or more political subdivisions An AA must include: Main office and branches Deposit-taking ATMs 5
6 Low- and Moderate-Income (LMI) Low-Income Less than 50% of the median family income Moderate-Income At least 50%, but less than 80% of the median family income 6
7 Community Development Categories Affordable Housing Community Services Economic Development Revitalize or Stabilize Neighborhood Stabilization 7
8 Community Development Primary purpose must be community development: The majority of the dollars or beneficiaries are related to community development or The expressed intent, structure, or result accomplishes community development 8
9 Community Development Loan Examples Loans for affordable housing Loans for community facilities that are located in LMI areas or that serve primarily LMI individuals 9
10 Community Development Loan Examples Loan promoting economic development, which meet the size and purpose tests: Size - Meets the size standards of the SBA s Development Company or Small Business Investment Company programs, or have gross annual revenues of $1 million or less Purpose - Promotes economic development 10
11 Qualified Investment Examples A bond which redevelops a low-income neighborhood An affordable housing-related bond A deposit in minority- or women-owned financial institutions A donation to an organization that provides services to LMI individuals 11
12 Community Development Services Service that: Meets the definition of community development Provides technical assistance 12
13 Community Development Services Examples Teaching financial education to LMI individuals Providing technical assistance on financial matters to a nonprofit organization serving LMI housing needs 13
14 Examples of Technical Assistance Serving on the board of directors Assisting in marketing financial services Contributing accounting services Providing services in an employee s areas of expertise at the institution Human resources, information technology, legal services, etc. 14
15 Performance Context Includes economic, demographic, and institution- and community specific information Performance context helps examiners understand: The needs and opportunities of the AA The capacities and constraints of the bank 15
16 Examination Types Small Bank Intermediate Small Bank Under $305 million $305 million to $1.22 billion Large Bank Over $1.22 billion Background Types Process Discussion 16
17 Examination Types (Continued) Limited Purpose/Wholesale Bank Bank offers a narrow product line Bank doesn t offer products to retail customers Strategic Plan Option Alternative assessment method available to any bank The written plan is approved by regulator The bank s performance is measure against the approved plan Background Types Process Discussion 17
18 Small Bank Evaluation Small Bank Lending Test: Loan to Deposit Ratio Assessment Area Concentration Borrower s Profile Geographic Distribution Response to Complaints Background Types Process Discussion 18
19 Intermediate Small Bank Evaluation Small Bank Lending Test Community Development Test Responsiveness to CD needs of AA through: CD Loans Qualified Investment CD Services Background Types Process Discussion 19
20 Large Bank Evaluation Lending Test Investment Test Service Test Background Types Process Discussion 20
21 Large Bank: Lending Test Assessment area concentration Geographic distribution of loans Borrower s profile Lending activity Responsiveness to credit needs of highly economically disadvantaged geographies, lowincome persons, and very small businesses Product innovation Community development lending activities Background Types Process Discussion 21
22 Large Bank: Investment Test Dollar amount of CD investments, including grants/donations Complexity and innovativeness of qualified investments Responsiveness of qualified investments to area needs Degree to which qualified investments are not routinely provided by private investors Background Types Process Discussion 22
23 Large Bank: Service Test Retail Services Changes in branch locations Accessibility of Delivery Systems Reasonableness of business hours and services in meeting area needs Community Development Services Background Types Process Discussion 23
24 Large Bank: Service Test Retail Services Changes in branch locations Accessibility of Delivery Systems Reasonableness of business hours and services in meeting area needs Community Development Services 24
25 Examiner Process Planning Data Validation Analysis Document 25
26 Discussion What have you found helpful in keeping CRA data organized? How could your help your bank improve its level of CRA activity? How can a bank coordinate with local organizations to perform community development activities? 26
27 CRA Steps for Success 1. Conduct outreach activities to better determine the needs of community 2. Create procedures for documenting activities Qualification as Community Development Impact 27
28 CRA Steps for Success 3. Provide community development activity training 4. Monitor and report activity levels 5. Review loans, investments, donations, and services for omitted activities 6. Provide examiners a list of all community development loans, investments, and services 28
29 Resources FFIEC CRA Webpage CRA Q&As (FDIC Manual) FDIC CRA Webpage FDIC CRA Ratings and Performance Evaluations FDIC Rules and Regulations, Part
30 Contact Information Scot Gotfredson (801)
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