The CRA Podcast with Linda Ezuka

The purpose of CRA data collection and maintenance is to enable examiners and the public to evaluate (through issuance of a CRA Performance Evaluation) whether a bank is helping to meet the credit needs of its communities through its small business and small farm loans. Accurate data leads to accurate assessments of fair lending and CRA lending performance. When data errors do occur, not only is t...

Are you looking for creative ways to reinvigorate your CRA committee meetings? It is crucial to foster communication and collaboration during these meetings, so people leave inspired and are motivated to get involved in your CRA program. But, this is easier said than done. Here are a couple strategies that help generate a larger impact during your CRA committee meetings. • Invite a CDFI to present...

When it comes to CRA program governance, there are three documents that every CRA program should have: a CRA policy, a CRA program plan and a CRA self-assessment. The CRA Policy: This document explains what you stand for, how you run your CRA program from the highest level, and how the program fits into your overall governance. The CRA Program Plan: This document explains the nitty gritty of your...

Once you have a solid self-assessment document, now it is time to socialize it. Not only will you increase awareness of your CRA program, but you will also be using it as a training tool. Make sure you break it down to the discrete applicable parts to avoid overwhelm. Consider setting up time with the following teams...and bring coffee! Emphasize their specific impact in the work and highlight you...

Does a blank page make you nervous? Yes, us too. Here are some documents you may want to reference (and even borrow the framework of!) to get you started on your CRA self assessment. • Peer Data: Download performance evaluations from similarly situated banks in your assessment areas. • Industry Data: Data from local community development think tanks, government agencies, or nonprofits. National st...

There just aren’t enough hours in the day. We get it. Many institutions believe they don’t have time to perform a self-assessment. What you may not know is that there are many types of self-assessments, some easier than others. Check out this list of assessment types to determine what kind of assessment will best fit your institution’s needs. Having a CRA self assessment is a best practice and a m...

Many banks make the mistake of spending too much time over-analyzing their performance history without giving equal airtime to formulating new strategies to address performance gaps within their CRA programs. It is imperative to create a self assessment that mimics a regulatory framework to assess your past performance. This document will not only get you exam-ready, but it will also serve as a fo...

Do you know what your bank’s strategy is? If this is not something that has been shared with you, reach out to leaders within your organization’s hierarchy to learn more. Ask questions like, “What are your division's key priorities?” and/or “What is the major initiative you are focusing on this year?” Take this information and brainstorm ways that you can align their strategies and initiatives wit...

The single most important CRA exam prep tool for you to consider is a CRA self-assessment. CRA self-assessments are assessments you perform on your own institution to understand your CRA strengths and performance gaps. If done correctly, the self-assessment mirrors an examiner’s approach to assessing your performance under the CRA. This assessment helps you understand how you’re currently performi...

Community Development Financial Institutions (CDFIs) were created to deliver responsible, affordable lending to help low-income, low-wealth and other disadvantaged people and communities join the economic mainstream. CDFIs can’t do this work alone. They are your partners in community development, not your competition! CDFIs make loans that you can’t make due to regulatory constraints, which makes...

Join the network of thousands of volunteers that ensures millions of low-income taxpayers receive billions of dollars in refunds, a network that helps the community meet their civic obligations as taxpayers and supports them on the path to financial security and opportunity. Consider volunteering for the Volunteer Income Tax Assistance (VITA) program. You can volunteer in your local community thro...

According to Experian data, if you have a credit card or two in your wallet, you're not alone. There is over $756 billion in outstanding credit card debt in the U.S., and approximately 95% of adults have a credit card account open in their name, according to Experian data from the third quarter (Q3) of 2020. In other words, every month should be financial literacy month! You don’t have to wait for...

The low-hanging fruit of community development services is…boards and committees! Many bank executives and employees are or could be serving on nonprofit boards and committees. These service hours and activities count towards the majority of community development services for most banks. Make sure you are diligently collecting this data and not letting it fall through the cracks. You may want to a...

Can the countless hours you’ve spent on the SBA Paycheck Protection Program (PPP) count as a community development service? The answer is yes and no! Although your bank worked seemingly around the clock last year to stand up the SBA PPP, none of the hours spent internally creating the loan application portals, working on underwriting and compliance or deploying loans under the program count toward...

On this week’s CRA Tip episode, we explore three community development services you might be surprised don’t count as CRA activities. Here is a brief overview: 1. Serving food at your local homeless shelter. This activity does not relate to the provision of financial services. 2. Helping build a Habitat for Humanity home during a weekend build. Again, this activity does not relate to the provision...

Take a second look at the retail distribution of your branches, ATMs and deposit-taking ATMs. Sometimes, it is helpful to map these data points to visualize how far away your branches and ATMs are from the next closest low- or moderate-income area. Now that you’re looking more closely, does your retail distribution arbitrarily exclude LMI geographies? Make sure to work closely with the executive m...

Last week, we talked about community development loan identification best practices – the low-hanging fruit that may already exist at your institution. Now, we switch our attention to proactive measures! Here are some best practices to increase the number of community development loan prospects that come across your desk. 1. AUTOMATE. Program your core system with community development definition...

You can’t do this work alone. In fact, the best CRA programs are built around key stakeholders working together towards the same CRA goals. As you know, mining for community development loans (CDL) can be a very manual and time-consuming process. This is especially true given that the subjective and technical definitions of a CDL aren’t often necessary within each credit approval memorandum write-...

Regulators are currently revisiting the way they define a community development loan (CDL) through CRA modernization efforts. So until there is more regulatory certainty, how do you determine how many CDL qualified loans are enough? While you can’t guarantee anything during the iterative swirl of CRA reform, this episode aims to give you a good idea of reasonable targets when executive management...

When looking through your loan portfolio for qualified community development loans, it is essential to have a strategic approach given limited time and resources to conduct a 100% review. A tactical approach can save you time and help you qualify more loans to support your bank’s lending performance. Start with these subsets of community development loan prospects to yield an efficient review: • L...

As you start building or refreshing your CRA program, these internal documents can serve as a guiding light. Gather these core documents and make sure you revisit them often as you initiate new programs and build your CRA culture throughout the bank. 1. Institution’s Strategic Plan & Goals 2. Marketing Plan and Activities 3. CRA Plan & Goals 4. CRA Self-Assessment 5. CRA Policies and Proce...

Managing the Community Reinvestment Act (CRA) program for your financial institution can be challenging, especially if you’re new to the CRA. To support you in your CRA journey, CRA Today and Kadince have partnered to provide informative content to highlight CRA best practices and ideas to guide your CRA program. We will be producing a new CRA Tip podcast episode every Tuesday morning, so you can...

BB&T and SunTrust formed Truist with a shared purpose – to inspire and build better lives and communities equally and equitably across all geographies. By providing grants in support of nonprofit organizations through the Truist Foundation, we can help grow their impact. In the first half of this episode, we will hear from Lynette Bell, President of the Truist Foundation. Learn more about why...

CRA Podcast Episode: EBA Fund: Converting the promise of entrepreneurship into assets that build economic inclusion and equity This episode interviews Brett Simmons, Fund Manager, and Joyce Klein, Chair of the Board of the EBA Fund and Director of Business Ownership Initiative, a program of the Aspen Institute. The podcast highlights the launch of Entrepreneur Backed Assets (EBA) Fund, is a new no...

CRA Podcast Episode: findCRA and First Western Trust-Partnering for Impact This episode interviews findCRA Co-Founders, Ben Loehle and Brian Waters, and Ted Gerbick, Director of Marketing & Philanthropic Giving and Emily Gardner, Senior CRA Analyst of First Western Trust. Together we explore tools for modern day CRA programs, regulatory reform and philanthropic priorities during the pandemic....