The CRA Podcast with Linda Ezuka

After collecting information about existing employee involvement through board service and volunteerism, it’s apparent you need to increase your bank’s community development services…but where do you start? First, look at your bank’s existing community development services and consider whether you can expand or deepen that relationship by providing additional services. Is the organization looking...

I estimate that at least 90% of banks under report their community development loans. Yes, that’s an alarming statistic, but I believe it's true. As I often say, the art of the CRA is not creating new programs, but actually unveiling what your bank is already doing to meet the needs of your community by the nature of opening your doors and deploying your core banking services. Recently, I have bee...

A key element of your CRA program is understanding that CRA is not always about creating new opportunities, but is about finding the opportunities that already exist. To do this, you should aim to give each team at least three CRA trainings a year. This will keep team members up-to-date on any new regulations and will help keep your program top of mind. Team members are more likely to forget about...

“One of the things that are appealing to me about being a Community Reinvestment Officer is helping those who are underserved,” says Melvin Hugans, a Community Reinvestment Officer at Thomasville National Bank. In honor of National Financial Capability Month, where financial institutions and organizations support programs that promote economic empowerment, host Linda Ezuka interviews Melvin Hugans...

“11% of students from low-income households graduate college,” says Abby Coyle. As a former educator for Teachers for America, Abby realized the equity gap in the education system. To close the gap, Abby co-founded ClassEquity, an online platform aimed to help students build financial literacy. Class equity enables students to open their own "bank account," through which they practice earning clas...

April 1st marked the start of National Financial Capability Month, a month during which organizations (especially financial institutions!) across the country focus on supporting programs that expand financial literacy, economic empowerment, and access to capital and credit for all consumers. You might be asking, “As a bank, what can we do to build financial capability in our community?” Luckily, t...

For the last thirty years, Tawalla Simmons has dedicated her career to serving others through CRA-inspired programs. Today, she is the president of Inspiring You to Greatness, a 501(c)3 nonprofit dedicated to educating low to moderate-income members of the community about credit, mortgage, and money literacy. As a previous mortgage broker, Tawalla saw firsthand the gap in education surrounding top...

It’s time to build your 2022 CRA strategy and action plan! Here are your next steps: Sign up to download the CRA plan resource. This list of questions will help prompt you as you start to build out your CRA plan. https://hub.cratoday.com/opt-in-c71cd533-9b19-4d80-89d9-43b2ec44f869 To prepare your approach, start by obtaining a copy of your bank’s strategic plans for 2022, if available. If a docume...

Build your CRA plan. You aren’t required under the Community Reinvestment Act to build a plan, but it’s an industry best-practice and will help take your CRA program to the next level. Keep your plan simple and don’t worry about making it perfect. Your plan can be one page or it can be 20; everything is up to you. As a general rule, you should start your plan with an overview of your CRA program....

Data submitted…now what? Now that you are confident in the reliability of the data, revisit your goals for the new performance year. It’s never-ending, I know! First, you’ll want to align your CRA strategy with the bank’s corporate strategy. As a member of the CRA team, you’re responsible for leading programs and building support in the community that helps your bank connect with potential custome...

Why does February only have 28 days? It seems so wrong as we are up against our March 1st CRA data reporting deadline! For those of you with CRA data reporting requirements, by now you have filed or might be working the weekend to prepare your small business, HMDA and community development loans data for FRB submission. Since time is of the essence, I recommend you do a "hail mary" last minute dat...

As you know, time is ticking away and soon you will be faced with scrubbing your CRA data to ready your small business, HMDA and community development loans data submission. Over the next few weeks, we will cover the most common mistakes and will provide some guidance to support you on your road to CRA data integrity. Here are four of the mistakes most commonly made by banks regarding their CRA da...

Let’s refocus our time on your CRA data integrity and, for some of you, your annual CRA data submission. For small and intermediate small banks, this means making sure your data is collected and maintained for future examiner review. For large banks, this means readying your data for FRB submission! By now, you are well on your way to testing, sampling and double checking your HMDA, small business...

Let's say you don't get to add to your CRA staff. What can you do to accomplish all of the work that you have before you? Today, I have three ways to support and supplement your CRA program. Leverage Bank Trainee Programs Chances are there is a trainee program at your bank, whether it’s for new officers of the bank, credit training, retail staff, etc. Oftentimes, these trainee programs have specia...

So, how do you actually build the culture of compliance within your bank? When you're looking at identifying your internal stakeholders, you'll want to look at the small business department, loan ops in particular. You could look at your home mortgage department, since they also have a loan ops group that touches the data on a daily basis as they originate loans. You also have your commercial lend...

So, how do you best go about dividing and conquering the work of a CRA officer? Many people inherit the CRA program and still have compliance responsibilities or dabble in BSA or share the titles of CRA officer and fair lending officer. Usually if you're just a team of one or even a partial position, you really have to do it all. From CRA data collection to data integrity testing to lending perfor...

Let's say you can't “add to staff” given resource constraints and you have to remain a mighty team of one doing “all of the things.” Sometimes you might feel like throwing in the towel…but not so fast! I have a few ideas for you. One common option is to engage with your line of business (LOB) management and team members to expand your internal CRA resources. You'll have to engage and inspire your...

We spent the last few CRA tips talking about community development finance. Today’s episode focuses on filling the gap when a seemingly undoable deal is before you. Our commercial lenders were trained to manage risk for the bank and to manage that risk based on various regulations, including the safety and soundness provisions. When a community development project is not quite doable, it may be up...

The best and most impactful community development finance projects are not done by any one bank, CDFI or community partner. The most monumental community-based projects are forged over time with strong leadership (and trust!) and the fortitude to manage the never-ending variables that are often required when driving impact into the most disadvantaged communities. This is where your internal and ex...

Once you have a good understanding of the technical aspects of the CRA and have stabilized your CRA program, now it's time to expand your reach into the community. Oftentimes, that will involve working alongside various stakeholders, who care deeply about serving lower income and disadvantaged communities. When working in community, you will likely be invited to participate in community redevelopm...

Cities for Financial Empowerment (CFE) Fund: https://cfefund.org/ The CFE Fund is a 501(c)3 nonprofit organization; our programmatic, research and policy efforts focus on designing, embedding and replicating financial empowerment initiatives within the fabric of local government. The CFE Fund’s national Bank On platform supports local coalition and financial institution efforts to connect consumer...

Take a deep breath. There is life after a failed CRA data integrity exam. I’ve been through a few rough ones over the past 27 years, and every bank ends up with a stronger program as a result. While I can’t promise a smooth path forward, I can offer a few quick tips to help you get to the root cause. First of all, you will want to identify the type of error that occurred: human or systemic. This w...

Gather all of your data-related resources into one place. Review the data-related policies and procedures. Review the content. What is missing? Is it accurate? When was it reviewed last? Does it have a revision date? Create a regular review schedule and make sure to involve major stakeholders (loan officers, underwriters, loan booking, documentation, your chief compliance officer, etc.). Identify...

I’ll bet you didn’t guess this one! The secret to a smooth CRA data integrity exam is...your loan operations team. Yep, loan ops! Wait, what? These team members are masterful at detail with their checklists, loan code sheets, document indexing system and digitalization platforms. They are your first call when you get your sampled lists from your examiners, and they carry the heavy burden of pullin...

As you know, before each exam, your regulators will conduct a review of your lending data to ensure that it is accurate enough to determine your lending performance. The regulators have a very specific approach that is delineated within the Consumer Compliance Handbook. If you haven’t downloaded this yet, I would encourage you to do so today. Here is the link and notation on where to find the spec...