An Introduction to the Community Reinvestment Act for Tribal Communities. Gloria Reynolds Community Affairs Specialist FDIC August 8 th 2013
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1 An Introduction to the Community Reinvestment Act for Tribal Communities Gloria Reynolds Community Affairs Specialist FDIC August 8 th 2013
2 What is the CRA? CRA stands for The Community Reinvestment Act of The regulations implementing the CRA were revised in 1989, 1995, 2005 & 2010.
3 What is the purpose of the CRA? The CRA states: 1) Regulated financial institutions are required by law to demonstrate that their deposit facilities serve the convenience and needs of the communities in which they are chartered to do business; 2) Convenience and needs include the need for credit services as well as deposit services; and
4 Purpose of the CRA cont d. 3) Regulated financial institutions have a continuing and affirmative obligation to help meet the credit needs of the local communities in which they are chartered.** **Consistent with safe and sound operation of such institutions.
5 Said Another Way Because banks take in deposits from across their communities, they must make loans available in those same communities! The practice of redlining was a key driver in the enactment of the CRA.
6 Muskogee, OK.
7 Low- and Moderate-Income What determines low- and moderateincome? Low-income means an individual income that is less than 50 % of the area median income* Moderate-income means an individual income that is between 50-80% of the area median income* *Median Family Income is adjusted for family size go to to find MFI for your area
8 Who are the Regulators? Federal Deposit Insurance Corporation (FDIC) Regulates non-federal Reserve member banks that are State-chartered Federal Reserve Bank (FRB) Regulates all bank holding companies, financial holding companies and state chartered member banks Office of the Comptroller of the Currency (OCC) Regulates banks with a national charter
9 Regulators but not for CRA National Credit Union Association (NCUA) Credit Unions not subject to CRA Consumer Financial Protection Bureau (CFPB) Banks larger than $10B for many consumer protection regulations but not CRA
10 Examination Categories Small Bank - Assets of less than $1.186 billion* as of December 31 st of either of the prior two calendar years. Intermediate Small Bank - Small Bank with assets of at least $296 million* as of December 31 st of both of the prior two calendar years, and less than $1.186 billion* as of December 31 st of either of the prior two calendar years Large Bank - assets of $1.186 billion* or more for each of the last two years *Annual adjustment of asset thresholds based on changes in the Consumer Price Index will be reported in the Federal Register. These asset-size threshold adjustments became effective on January 1, 2013.
11 Assessment Area Assessment Area (AA) - the geographic area in which CRA performance is evaluated. The AA must include geographies where the bank has its main office, its branches, and deposit taking ATMs, as well as surrounding geographies in which the bank has originated or purchased a majority of its loans.
12 The Performance Context The performance context is information about the bank, its community and its competitors and is included in the examination report. The information establishes base-line data from which to judge a bank s performance. Includes demographic, geographic, market, and community needs information as well as bank capacity. Community contacts are a valuable source of information.
13 Small Banks and Intermediate Small Banks
14 CRA Examinations - Small Bank Small Bank Lending Test: 1. Loan-to-deposit ratio 2. Lending in the assessment area ( in/out ratio ) 3. Borrower distribution 4. Geographic distribution 5. Resolution of consumer complaints
15 Small Bank Continued Loans reviewed are those that are the major business line(s) of the bank. Home lending almost always reviewed Qualified community development loans, investments and services are not considered, but at bank s request may be reviewed to enhance a Satisfactory rating to an Outstanding
16 CRA Examinations - ISB Two-part assessment: 1. Lending Test - the same as the Small Bank Lending Test (5 criteria) 2. Community Development Test - includes the number and dollar amount of community development ( CD ) loans & investments and the level of CD services
17 ISB vs. Large Bank Ratings The chart below illustrates the components and weighting of the ISB examination and the large bank examination. The test is designed to reduce the data burden on mid-sized banks and increase their options for addressing local CRA issues
18 Large Banks
19 CRA Examinations Large Bank Three part assessment: 1) Lending Test Core & CD Lending 50% of weight 2) Investment Test CD 25% of weight 3) Service Test CD and Non-CD 25% of weight
20 Large Bank Lending Test
21 Lending Test TYPES OF LOANS: The Lending Test evaluates a bank s record of helping to meet the credit needs of its AA through its lending activities by considering the bank s: Home mortgage loans Small business loans including loans to small farms, and Community Development Loans plus any other consumer loan type if it is a substantial part of the bank s loan portfolio
22 Lending Test Cont d. Consideration for CD loans: Number of loans and the complexity and innovation involved in making the loan Use of innovative or flexible lending practices in a safe and sound manner to address credit needs of low- and moderate-income ( LMI ) individuals or geography
23 Lending Test Cont d. Lending activity evaluated on WHERE & TO WHOM LOANS ARE MADE: Proportion of total loans within AA Distribution within low, moderate, middle and upper-income census tracts Distribution of home mortgage loans to different individuals of different income levels Distribution of business loans to different sizes of businesses and farms
24 Community Development Defined 1) Affordable housing for LMI individuals and families 2) Community services targeted to LMI individuals 3) Activities that promote economic development by financing small businesses or small farms (size standard meeting SBA SBDC or SBIC programs or gross annual revenues of $1M or less).
25 Community Development Cont d. 4) Activities that revitalize or stabilize: LMI geographies Designated disaster areas Distressed or underserved rural middle-income geographies, based on rates of poverty, unemployment and population loss or population size, density and dispersion, where the activity helps meet essential community needs, including the needs of LMI populations
26 Community Development Cont d. 5) Loans, Investments and Services in target areas defined by the Neighborhood Stabilization Program Support, enable or facilitate projects or activities in target areas under the HUD administered Neighborhood Stabilization Program (NSP) Are provided no later than 2 years after the last date NSP appropriated funds are required to be spent by grantees; and Benefit LMI and middle-income individuals and geographies
27 Where CD Activities Take Place Consideration for CD loans, investments and services may be given if made in or benefit: The bank s AA A greater statewide or regional area that includes the bank s AA Designated Major Disaster Areas as defined by FEMA for 36 months following designation. The FEMA website lists designated disaster areas. Distressed & Underserved Rural Middle-Income Geographies as designated by the regulators a county that has an unemployment rate of at least 1.5 times the national average a poverty rate of 20% or more population loss between censuses of 10% or more; net migration rate of 5%.
28 More Examples of CD Loans Loans to not-for-profit organizations serving primarily LMI housing or other community development needs Loans to financial intermediaries including CDFIs, CDCs, and community loan funds or pools Loans to local, state, and tribal governments for community development activities
29 Large Bank Investment Test
30 CD Qualified Investments Has a primary purpose of community development Is a lawful investment, deposit, membership share, or grant
31 Examples of Qualified Investments Investments in or grants to: Financial intermediaries that lend in LMI areas or to LMI individuals in order to promote community development Organizations that promote economic development by financing small businesses Facilities that promote community development in LMI areas for LMI individuals Projects eligible for low-income housing tax credits.
32 Large Bank Service Test
33 The Service Test The Service Test evaluates a bank s record of helping to meet the financial services needs of its AA by analyzing: The availability and effectiveness of a bank s systems for delivering retail banking services, and The extent and innovative nature of its community development services
34 Community Development Service Has a primary purpose of community development Is related to the provision of financial services Has not been considered in the bank s retail banking services
35 Examples of CD Services Providing technical assistance on financial matters to nonprofit, tribal or government organizations serving LMI housing or economic revitalization and development needs Serving on a board of organizations facilitating affordable housing construction and rehabilitation or development of affordable housing Developing and teaching financial education curricula for LMI individuals
36 Discriminatory Practices & CRA Equal Credit Opportunity Act or Fair Housing Act (discrimination on prohibited basis) Section 5 Federal Trade Commission Act (unfair or deceptive acts) Section 8 of Real Estate Settlement Procedures Act (kickback, fee splitting, unearned fees in settlement services) Truth in Lending Act s consumer right of rescission Reg Z Truth in Lending (security interest in consumer s principal dwelling) Home Ownership and Equity Protection Act - Reg Z Truth in Lending (high APR and fees)
37 Public Access to Information Public Notice: A posted NOTICE that the public is entitled to certain information about the bank s operations and performance under the CRA must be posted in each of the bank s branches Public File: Contains information about the institution s CRA performance. Must be made available for viewing by members of the community Ensures public access to timely and accurate CRA information about the institution
38 Public Access to Information Cont d. The public has the right to comment on a bank s performance under the CRA, and to comment on any application submitted to the federal bank regulatory agencies to acquire another bank, add a branch, etc. For exam schedules, CRA data, HMDA data, and application information, see the agencies websites:» (CRA and HMDA data)»
39 Tribal Communities & the CRA 49 States in the U.S. operate under English Common Law Louisiana is governed by the Napoleonic Code Native American Tribes are sovereign nations
40 Attracting Loans & Investments Banks make a return from loans & investments And receive CRA consideration for making loans and investments that have a community development purpose How can a Tribe attract loans and investments for use in its communities?
41 Sovereign Immunity Choice of Venue Choice of Law
42 Safe & Sound Banking Practices The Five C s of Underwriting: 1. Capacity 2. Capital 3. Collateral 4. Conditions 5. Character
43 Capacity Osage Nation Headrights
44 Collateral - Real Property/Land Cherokee, Chickasaw, Choctaw, Creek and Seminole Oklahoma s remaining 33 tribes
45 Collateral Chattel Not land or buildings Equipment Commercial Vehicles Furniture and Fixtures Inventory and Receivables Livestock and Harvested Crops
46 Contracts & Enforcement Lien Records and Searches Lien Enforcement
47 Indian Business Alliances State-based coalitions Support Native American business & economic development
48 THANK YOU! Gloria Reynolds Community Affairs Specialist Dallas Region FDIC (972)
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