CDFI Community Development Financial Institutions By: Holly R. Logue IBAT Annual Convention September 21, 2015
Introduction Holly R. Logue Financial Institution Strategies Group, LLC CDFI Banks in Mississippi, Louisiana, Alabama, Tennessee, and Arkansas (601) 427-9122 (direct) (601) 622-6400 (cell) hlogue@fistrategies.net
What is a CDFI? Financial institutions devoted to promoting community development in economically distressed areas through the provision of financial products and services. Types of CDFIs: Banks Credit Unions Loan Funds Venture Capital Funds CDFI Certification is a designation conferred upon an Applicant by the CDFI Fund, a division of the U.S. Treasury Department
Seven Eligibility Criteria Legal Entity Automatically satisfied by all banks Primary Mission Must demonstrate a primary mission of promoting community development in its Target Market A primary mission, not the primary mission! Can take the form of a Board Resolution All Affiliates must adopt primary mission statement.
Seven Eligibility Criteria Financing Entity FDIC insured banks automatically satisfy this criteria Target Market Identify Investment Area or Targeted Population At least 60% of loans and deposits Can have multiple Investment Areas to reach 60%
Seven Eligibility Criteria Accountability Must maintain accountability to its Target Market through: Governing Board or Advisory Board (30% outside directors) Focus Groups or Community Meetings Customer Surveys Development Services Must provide development services in conjunction with financial activities. Examples include: One-on-one credit counseling FDIC Money Smart IBAT s Teach the Teacher Program
Seven Eligibility Criteria Non-governmental entity No government controls election of the Board Board members are not government officials Charter/Bylaws don t require Board members to be elected officials No government entity provides greater than 50% capital/operating budget No government entity manages operations
Can be submitted at any time Applications To qualify as a Certified CDFI for next round of BEA must be certified by FYE of preceding year. Typically allow 90 days for Certification Submitted to CDFI Fund ( Word Application, Excel Spreadsheet) Certification currently valid for three years Proposed annual re-certification process
Advantages of Certification Regulatory Exemption : ATR/QM Bank Enterprise Award Program: Priority Consideration CDFI Program Award Eligibility Automatic eligibility for CDE status under New Market Tax Credits Program Potential CRA benefits
Certified CDFIs as of July 31, 2015 Banks or Thrift 110 Credit Union 256 Depository Institution Holding Company 61 Loan Fund 514 Venture Capital Fund 14 Total Number of CDFIs 955
Texas Counties 110/254 Fully Qualified Counties 1. Aransas 2. Armstrong 3. Atascosa 4. Bandera 5. Baylor 6. Borden 7. Brazos 8. Briscoe 9. Brooks 10. Caldwell 11. Calhoun 12. Callahan 13. Cameron 14. Camp 15. Castro 16. Cherokee 17. Childress 18. Cochran 19. Coke 20. Coleman 21. Collingsworth 22. Comanche 23. Concho 24. Coryell 25. Cottle 26. Crockett 27. Crosby 28. Culberson 29. Dawson 30. Delta 31. Dickens 32. Dimmit 33. Duval 34. Eastland 35. Edwards 36. El Paso 37. Falls 38. Fisher 39. Floyd 40. Foard 41. Frio 42. Garza 43. Glassock 44. Gonzales 45. Hall 46. Hardeman 47. Haskell 48. Hidalgo 49. Houston 50. Hudspeth 51. Hutchinson 52. Jefferson 53. Jim Hogg 54. Jim Wells 55. Jones 56. Kent 57. King 58. Kinney 59. Kleberg 60. Knox 61. Lamb 62. LaSalle 63. Liberty 64. Live Oak 65. Lynn 66. McCulloch 67. McLennan 68. McMullen 69. Madison 70. Marion 71. Matagorda 72. Maverick 73. Motley 74. Nacogdoches 75. Nueces 76. Oldham 77. Pecos 78. Polk 79. Potter 80. Presidio 81. Real 82. Red River 83. Reeves 84. Refugio 85. Robertson 86. Runnels 87. Sabine 88. San Augustine 89. San Jacinto 90. San Patricio 91. San Saba 92. Shelby 93. Smith 94. Starr 95. Sterling 96. Stonewall 97. Swisher 98. Terrell 99. Throckmorton 100. Uvalde 101. Val Verde 102. Walker 103. Waller 104. Webb 105. Wichita 106. Wilbarger 107. Willacy 108. Yoakum 109. Zapata 110. Zavala
Map of Qualified Census Tracts
Houston Qualified Census Tracts (Harris County)
DFW Qualified Census Tracts (Dallas and Tarrant Counties)
San Antonio- Qualified Census Tracts (Bexar County)
Austin - Qualified Census Tracts (Travis County)
BEA Awards (Bank Enterprise Award Program) The BEA Program provides financial incentives (monetary awards in the form of grants) to FDIC insured depository institutions for increasing their investments in CDFIs and for increasing their own lending, investment and service activities within Distressed Communities. $411 million awarded since inception of BEA in 1994 Annual appropriation by Congress All FDIC insured banks may apply; CDFI banks are given priority over non-cdfi banks Awards based on increase in Qualified Activities year over year
BEA Awards Awards based on Qualified Activities that have already been completed Formula driven by Qualified Activity from Baseline Period to Assessment Period Awards are booked to income Equivalent amount must be deployed in future Qualified Activities Minimal burden 12 months to deploy equivalent amount; 18 months to report
BEA Award Snapshot: FY2009-FY2014 Since 1996, the CDFI Fund has granted $411 million in BEA Program awards over 18 rounds. YEAR NUMBER OF AWARDS % OF APPLICANTS AWARDED NUMBER OF CDFIs/MDIs AMOUNT AWARDED AVERAGE AWARD SIZE MAXIMUM AWARD AMOUNT 2009 55 95% 37/24 $22 million $406,042 $700,000 2010 70 92% 34/25 $25 million $357,249 $600,000 2011 78 89% 41/22 $22 million $281,487 $500,000 2012 59 83% 34/19 $18 million $304,559 $415,000 2013 89 88% 38/21 $17 million $200,574 $323,000 2014 69 71% 48/21 $18 million $258,962 $355,000
BEA Awards BEA Program Distressed Communities are census tracts with: Among other criteria: At least 30% of population living in poverty, and Unemployment rate at least 1.5 times the national average More severe level of distress than what is required for Certification
Award Priority Rewards actual increases in dollar volume of Qualified Activities in three categories: FIRST PRIORITY CDFI RELATED ACTIVITIES: Equity Investments CDFI Support Activities CDFI Credit Union CDs Loans to non-bank CDFIs
Award Priority SECOND PRIORITY DISTRESSED COMMUNITY FINANCING ACTIVITIES : Affordable Housing Loans Affordable Housing Development Loans Small Business Loans Home Improvement Loans Education Loans Commercial Real Estate Loans Small Dollar Consumer Loans
Award Priority THIRD PRIORITY SERVICE ACTIVITIES : Deposits Community Services Financial Services Targeted Financial Services Targeted Retail Savings/Investment Products TYPICALLY NOT FUNDED
Worksheet 1: Estimated BEA Award Calculation Applicant Organization Name: Small Bank CDFI Bank CDFI RELATED ACTIVITIES A B C D E F Baseline Period Assessment Period Estimated Aw ard Change in Activity Reporting 2013 2014 Aw ard Percent Amount Equity Investments (CEI)/ Equity-Like Loans 1 (ELL)/ Grants (CG) No $ - 15% 0 CDFI Support Activities: Loans (LNS), CDFI 2 Deposits/Shares (DS), Technical Assistance (TAC) Yes $ - $ 250,000 $ 250,000 18% $ 45,000 3 Estimated Aw ard Amount for CDFI Related Activities: $ 45,000 DISTRESSED COMMUNITY FINANCING ACTIVITIES A B C D E F Baseline Period Assessment Period Change in Activity Reporting 2013 2014 Priority Factor Weighted Value 4 Affordable Housing Loans (AHL) No $ - 5 0 Affordable Housing Development Loans and 5 Project Investments (AHD) No $ - 5 0 6 Small Dollar Consumer Loans (SDL) No $ - 5 0 Small Business Loans and Project 7 Investments (SBL) Yes $ 1,000,000 $ 2,000,000 $ 1,000,000 5 $ 5,000,000 8 Home Improvement Loans (HIL) No $ - 5 0 9 Education Loans (EDU) No $ - 5 0 Commercial Real Estate Loans and Project 10 Investments (CRE) No $ - 5 0 11 Total Score: $ 5,000,000 Estimated Aw ard Amount for Distressed Community Financing Activities 9% $ 450,000 SERVICE ACTIVITIES A B C D E F Baseline Period 2013 Assessment Period 2014 Change in Activity Priority Factor Weighted Value Reporting 12 Deposits (D) No $ - $ 5 0 13 Community Services (CS) No $ - $ 5 0 14 Financial Services (FS) No $ - $ 5 0 15 Targeted Financial Services (TFS) No $ - $ 5 0 Targeted Retail Savings/Investment Products 16 (TSP) No $ - $ 5 0 17 Total Score: $ - 18 Estimated Aw ard Amount for Service Activities $ - ESTIMATED AWARD 19 PRIORITY ONE AWARD (CDFI Related Activities) $ 45,000 20 PRIORITY TWO AWARD (Distressed Community Financing Activities)* $ 450,000 21 PRIORITY THREE AWARD (Service Activities) $ - 22 TOTAL ESTIMATED AWARD $ 495,000
BEA Qualified Tracts - Austin
BEA Qualified Tracts - DFW
BEA Qualified Tracts - Houston
BEA Qualified Tracts - McKinney
BEA Qualified Tracts San Antonio
BEA Qualified Tracts South Texas
CDFI Program Awards (FA/TA) Awards up to $2 million (FA) or $125,000 (TA) CDFI Fund Awarded over $1.3 billion since inception. A CDFI may use an FA Award for: Financing capital Loan loss reserves Capital reserves Operations A CDFI may use a TA Award for: Equipment purchase Consulting or contracting services Salaries and benefits of certain personnel; and/or to train staff or board members
Other Programs for CDFIs New Markets Tax Credit Programs Texas 126 awards totaling $663,493,150 BEA -$15 million last awards in 2004 Missed Opportunity for Texas Banks FA- $34 million credit unions and loan funds
Thank You! Holly R. Logue Financial Institutions Strategies Group, LLC 992 Northpark Drive, Suite C Ridgeland, MS 39157 hlogue@fistrategies.net (601) 427-9122 (direct) (601) 622-6400 (mobile) (601) 510-9163 (fax)