Community Development Lending and CRA
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Community Development Lending and CRA 2008 NC Affordable Housing Conference October 16, 2008 Bonita Irving District Community Affairs Officer Office of the Comptroller of the Currency. Topics to be Covered. 2005 Changes to the CRA Regulation

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Community Development Lending and CRA 2008 NC Affordable Housing Conference October 16, 2008

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Community development lending and cra 2008 nc affordable housing conference october 16 2008

Community Development Lending and CRA

2008 NC Affordable Housing Conference

October 16, 2008

Bonita Irving

District Community Affairs Officer

Office of the Comptroller of the Currency


Community development lending and cra 2008 nc affordable housing conference october 16 2008

Topics to be Covered

  • 2005 Changes to the CRA Regulation

  • 2007 Proposed Changes to Interagency Questions and Answers

  • Emerging Issues


Community development lending and cra 2008 nc affordable housing conference october 16 2008

Changes to the Regulation - 2005

  • Changed small bank size to < $1 billion

  • Established new category of banks – “intermediate small banks”

  • Expanded the definition of community development

  • Addition of illegal credit practices language


Cd definition effective september 1 2005

CD Definition – Effective September 1, 2005

  • Affordable housing for low- or moderate-income individuals

  • Community services for low- or moderate-income individuals

  • Activities that promote economic development by financing small businesses/farms

  • Activities that revitalize or stabilize –

    • LMI geographies

    • Designated disaster areas

    • Distressed or underserved nonmetropolitan middle-income geographies designated by the agencies


Community development lending and cra 2008 nc affordable housing conference october 16 2008

  • List of Distressed and Underserved Geographies available on FFIEC Website (www.ffiec.gov/cra)

    • Reviewed and updated by the agencies annually and posted to the website

    • FFIEC geocoder identifies if address is in distressed/underserved geography

  • One-year lag period in effect for the calendar year following the date of removal from the list


Distressed geographies

“Distressed” Geographies

Distressed Nonmetropolitan Middle-Income Geographies:

  • Meet one or more of triggers for:

    • Unemployment rate

    • Poverty rate

      • OR

    • Population loss or net migration loss


What qualifies as community development

What Qualifies as Community Development?

Activities that revitalize and stabilize distressed nonmetropolitan middle-income geographies by:

  • Helping to attract new, or retain existing, residents and businesses (including by providing jobs) or is part of bona fide plan to revitalize or stabilize the geography

  • Providing long-term direct benefit to entire community, including low- and moderate-income individuals and neighborhoods


Underserved geographies

“Underserved” Geographies

Underserved Nonmetropolitan Middle-Income Geographies:

  • Based on population size, density, and dispersion

  • Population so small, thin and distant

    from a population center that is has difficulty

    financing essential community needs


What qualifies as community development1

What Qualifies as Community Development?

Activities that revitalize and stabilize underserved nonmetropolitan middle-income geographies by:

  • Meeting essential community needs, including the needs of LMI individuals

  • Facilitating the construction, expansion, improvement, maintenance, or operation of essential infrastructure or facilities for health services, education, public safety, public services, industrial parks or affordable housing

    • The infrastructure or facility must serve LMI individuals and must provide a long-term direct benefit to entire community, including LMI individuals and neighborhoods.


What are designated disaster areas

What are Designated Disaster Areas?

  • Major disaster area designated by federal government

  • List of FEMA-declared disaster areas available on FEMA’s website (www.fema.gov)


What qualifies as community development2

What Qualifies as Community Development?

  • Activities that revitalize and stabilize designated disaster areas by:

    • Helping to attract new, or retain existing, residents and businesses (including by providing jobs) and is related to disaster recovery - or be part of bona fide plan to revitalize or stabilize the geography

      • Must provide a long-term direct benefit to the area

      • Greater weight to those activities that benefit LMI individuals and areas

      • Must be provided within 36 months following the date of designation – however, this may be extended


Community development lending and cra 2008 nc affordable housing conference october 16 2008

Proposed Interagency CRA Q&As

  • Issued for comment on July 11, 2007

  • Proposed nine new Qs & As

  • Substantive and technical revisions to some existing Qs & As

  • Comment period closed on September 10, 2007

  • Interagency group continues to work to finalize


Minority or women owned institutions q a

Minority- or Women-Owned Institutions Q&A

  • Proposed New Q&A § __.12(g) – 4

  • Addresses activities of a majority-owned institution with a minority- or women-owned institution or low-income credit union (“MWLI”)

    • Participating institution will receive positive CRA consideration even if minority- or women-owned bank is not in its assessment area

    • Consider capital investments, loan participations, and other ventures

    • Must help meet credit needs of the communities in which minority- or women-owned institutions or low-income credit union are located


Minority or women owned institutions q a1

Minority- or Women-Owned Institutions Q&A

Examples:

  • Making a deposit or capital investment

  • Purchasing a participation in a loan

  • Loaning an officer or providing other technical expertise to assist an “MWI” in improving its lending policies and practices

  • Providing financial support to enable an “MWI” to partner with schools or universities to offer financial literacy education to members of its local community

  • Providing free or discounted data processing systems, or office facilities to aid an “MWI” in servings its customers


Retail loans as cd loans at isbs q a

Retail Loans as CD Loans at ISBs Q & A

  • Proposed New Q & A §__.12(h) – 3

  • Addresses the treatment of retail loans that meet a community development purpose in ISBs

  • Such loans can be considered as either:

    -Retail (home, business, or farm) ----- Lending Test

    -Community Development (meet CD definition) ----- CD Test


Community development lending and cra 2008 nc affordable housing conference october 16 2008

Examples of Other Loan Data Q & A

  • Proposed New Q&A § __.22(a)(2) – 4

  • Provides examples of other loan data

    • Loans funded for sale to secondary markets not reported under HMDA

    • Unfunded loan commitments

    • Letters of credit

    • Commercial and consumer loans

    • Set-aside loans that don’t meet the primary CD purpose

    • Business/farm loans secured by residential real estate

    • LOC increases over the CRA loan limit


Community development lending and cra 2008 nc affordable housing conference october 16 2008

Participations, Renewals, and Refi Qs & As

  • Proposed New Q&A § __.22(a)(2) – 6

    • Consider and report amount of participation purchased

  • Proposed New Q&A § __.42(b)(2) – 4

    • Use entire amount of lead loan to determine if participation purchased is a small loan to a business or a CD loan (over $1MM cutoff for large banks

  • Proposed New Q&A § __.42(b)(2) – 5

    • Report CD loan renewals and refinances

  • Proposed New Q&A § __.22(a)(2) – 7

    • How to report small business/small farm loan refinances when residential real estate is taken as an abundance of caution


New examples of economic development

New Examples of Economic Development

  • Proposed Revision Q&A § __.12(g)(3) -1

  • Adds the following examples of entities in which investments in or loans to will be presumed to promote economic development:

    • Rural Business Investment Company (RBIC)

    • New Markets Tax Credit-Eligible Community Development Entity (CDE)


New examples of cd loans

New Examples of CD Loans

  • Proposed Revision Q&A § __.12(h) -1

  • Adds the following examples of loans to:

    • Financial intermediaries including New Markets Tax Credit-eligible CD Entities (CDEs)

    • Businesses, in an amount > $1 million, when made as part of the SBA’s 504 Certified Development Company program


New examples of qualified investments

New Examples of Qualified Investments

  • Proposed Revision Q&A § __.12(t)

  • Adds the following examples of investments, grants, deposits or shares in or to:

    • Financial intermediaries (including New Markets Tax Credit-eligible CD Entities)

    • CD venture capital companies that promote economic development by financing small businesses


New examples of cd services

New Examples of CD Services

  • Proposed Revision Q&A § __.12(i) – 3

  • Adds the following example of:

    • Increasing access to financial services by opening or maintaining branches or other facilities that help to revitalize or stabilize a LMI geography, designated disaster area, or a distressed or underserved nonmetropolitan middle-income geography

      • unless has been considered in the evaluation of the institution’s retail banking services under the Service Test


National or regional cd fund q a

National or Regional CD Fund Q&A

  • Proposed New Q&A § __.23(a) – 2

  • If make a loan or investment in national or regional CD fund:

    • Should demonstrate that the investment meets the geographic requirements of the CRA reg by:

      • Benefiting one or more of the institution’s AA(s) or a broader statewide or regional area that includes the institution’s AA(s)


Community development lending and cra 2008 nc affordable housing conference october 16 2008

Emerging Issues – Foreclosures and CRA

  • Examples of CD Services added to existing Q&A ___.12(i) – 3: “What are examples of community development services?”

    • Credit counseling to low- or moderate-income borrowers in avoiding foreclosure on their homes

    • Providing foreclosure prevention programs, including loan modifications and restructurings, to low- or moderate-income borrowers who are facing foreclosure


Community development lending and cra 2008 nc affordable housing conference october 16 2008

Emerging Issues – Foreclosures and CRA

  • Example of lending programs added to existing Q&A ___ .22(a) – 1: “Are there types of lending activities that help meet the credit needs of an institution’s assessment area(s) and that may warrant favorable consideration as activities that are responsive to the needs of the institution’s assessment areas?”

    • Establishing loan programs that provide relief, for example, through loan refinancings, restructures, or modifications, to homeowners who are facing foreclosure on their primary residences


Community development lending and cra 2008 nc affordable housing conference october 16 2008

Emerging Issues - Foreclosures and CRA Reg

  • Proposed Amendment to the CRA Regulation

  • CRA consideration for community development activities that revitalize and stabilize middle-income geographies that are significantly impacted by the foreclosure crisis


Emerging issues demographic economic trends

Emerging Issues – Demographic & Economic Trends

  • Unemployment

  • Neighborhood Stabilization Initiatives

  • Preservation of Affordable Rental Housing


Questions

QUESTIONS?????????????


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